Implementation of ICD-10s has been delayed “indefinitely.” Rather than opine on whether that’s a good thing or a bad thing, I will note that it creates an opportunity for a simple but powerful improvement in the value of the coding.
Caveat: I am not a coding expert (I don’t even play one on TV) so there might be something wrong with this idea. The specific reason for the post is to find out whether there is some reason this can’t be done, given the value of doing it. (I am so unfamiliar with coding that it is possible this is already being done and I’m the last guy to find out about it, in which case perhaps John and Matthew would be kind enough to remove it.)
Quite simply, how about adding an optional “R” for “rule-out” after the codes? For instance, today if a patient gets tested for diabetes and it turns out that he HAS diabetes, he gets coded “250” in the ICD-9s. Whereas if it turns out the patient does NOT have diabetes, he still gets coded “250.” My proposal would code that (in ICD-9s) 250R.
By contrast, giving two opposite diagnoses the same code creates a cascading set of problems, in outcomes measurement, risk scoring, registries, disease management, reimbursement, and predictive modeling, problems that will be exacerbated as risk shifts down to the provider level and payors move to outcomes-based reimbursement.
After years of telling us they are serious this time and everyone in the health care system had better be ready on time to implement the new disease coding system, CMS said today the whole project is going to be delayed indefinitely.
The new ICD-10 system requires payers and providers to convert from the old system of 13,000 codes to the new system of 68,000 codes.
All payers and providers were supposed to be ready by October 1, 2013. The acting CMS Administrator said, “There is a concern that folks cannot get their work done around meaningful use [of information technology], ICD-10 implementation, and be ready for [insurance] exchanges. So we decided to listen and be responsive.”
Apparently, a new timeline will be developed through a “rule making process.”
Fine, but that has not been the message for months now and lots of people have spent lots of money for apparently no good reason.
The concerns that particularly physicians would not be ready on time have not been minor. CMS conducted a survey between January and March of 2011 that clearly showed there were big problems ahead. But in the year since that survey, they continued to tell stakeholders to keep going ahead full speed, spending big money to be ready.
But in the last few weeks, the American Medical Association has been sounding the alarm–their people wouldn’t be ready.
Sounds like the lowest common denominator in the health care system wins out.
Here are the results from a survey CMS conducted from January to March of 2011 by type of industry participant. AHIP is the insurance industry trade association, HBMA and AAPC are associations of industry coding and billing providers, ACP is the American College of Physicians and the AMA is the American Medical Association. The survey also measured readiness for the Version 5100 standards for electronic health transactions that were effective in January 2012, but for which enforcement has been delayed until March 31, 2012.
If flipping the switch on ICD-10 come Oct. 1, 2013 will be such a disaster as groups like the AMA claim it will be, then why didn’t it bring down the European and Asian health systems that implemented their own flavors of ICD-10 years ago?
The reporter in me – especially when hearing people couch ICD-10 in terms like “unfunded mandate” and “sky-is-falling” hyperbole – suspects it’s all about politics. During the course of debate in these times, it seems as if people on both the left and right resort to browbeating rhetoric faster than I’ve ever seen in my life. And why not? Reciting the catchphrase du jour requires far less reasoning than a well-constructed, original thought.
2011 was a year of change and tumult. For a day by day look at the top stories of 2011, check out this impressive chart from the UK Guardian.
It was a year in which the economy sputtered worldwide, the Arab Spring toppled several regimes, and unprecedented acts of nature (severe weather, earthquakes) caused billions in worldwide damage.
What about the world of healthcare IT?
In 2011, Meaningful Use and Certification accelerated healthcare IT adoption and doubled implementation of EHRs throughout the country. Every aspect of the industry was stressed along the way
Vendors were challenged to add the features necessary for certification resulting in some “haste makes waste” lack of usability and workflow integration. GE admitted its faults and should be congratulated for its honesty, since many other vendors had the same problems but did not communicate them.
IT organizations created productivity miracles to meet meaningful use timeframes with limited staff and limited budgets. Many organizations will apply their meaningful use payments to general operations and not IT department budget increases, so the sacrifice of IT staff may remain unrecognized.
Providers had to radically change workflows to accommodate new business processes, resulting in staff turnover and short term frustration.
Every year I write about the projects and trends which keep me up at night. Here’s my list for FY12:
1. Workforce recruitment/retention – $27 billion in stimulus funds from HITECH have increased demand for experienced IT staff to implement and support electronic health records. In many ways, it’s a mini “dot com” boom for healthcare IT experts. This makes recruiting and retaining qualified staff even harder. Tomorrow, I’m meeting with a consulting team to formulate an FY12 workforce strategy.
2. 5010/ICD10 – 5010 describes a set of X12 standards used for administrative transactions (benefits/authorization. referral authorization, claims). Payers and providers must support 5010 by January 1, 2012 or risk disruption of the revenue cycle. BIDMC completed all its 5010 work and is now in final testing with every payer. Most payer and provider stakeholders will meet the deadline, but significant resources have been pulled from other projects. ICD-10 implementation is required by October 1, 2013 and I’ve written about those challenges. Billions will be spent, many healthcare IT projects will be deferred for the next 2 years, and the end result will be no cost savings (coding costs are likely to increase 50%), no quality improvement, no increased safety, and no efficiency gains. If we complete the ICD-10 project on time, no one will notice, but customers will all be angry at the IT department (and the CIO) for the work on other projects that was deferred.
3. Vendor Product Quality – over the past year, I’ve had several bad experiences with infrastructure and application vendors which delivered products that did not have the reliability, security, or performance promised. Why?
* the pace of innovation is so fast, that time for quality assurance is diminished
* the economy has stressed companies and they are focused on making as many sales as fast as they can while controlling development and support costs
On October 1, 2013, the entire US healthcare system will shift from ICD9 to ICD10. It will be one of the largest, most expensive and riskiest transitions that healthcare CIOs will experience in their careers, affecting every clinical and financial system.
It’s a kind of Y2k for healthcare.
Most large provider and payer organizations, have a ICD10 project budget of $50-100 million, which is interesting because the ICD10 final rule estimated the cost as .03% of revenue. For BIDMC, that would be about $450,000. Our project budget estimates are about ten times that.
CMS and HHS have significant reasons for wanting to move forward with ICD10 including
1) easier detection of fraud and abuse given the granularity of ICD10 i.e. having 3 comminuted distal radius fractures of your right arm within 3 weeks would be unlikely
2) more detailed quality reporting
3) administrative data will contain more clinical detail enabling more refined reimbursement
Large healthcare organizations have already been working hard on ICD10, so they have sunk costs and a fixed run rate for their project management office. At this point, any extension of the deadline would cost them more.
Most small to medium healthcare organizations are desperate. They are consumed with meaningful use, 5010, e-prescribing, healthcare reform, and compliance. They have no bandwidth or resources to execute a massive ICD10 project over the next 2 years.