By Ken Congdon
I decided to wait to weigh in on the ICD-10 delay until the dust settled around the topic. But, now with the SGR “Doc Fix” bill being passed by both the House and the Senate, it seems almost certain that an industry-wide transition to the ICD-10 code set will be pushed back by another year — at the very least. The only thing that stands in the way of this bill becoming a law is a presidential veto, and that seems highly unlikely.
I’m sure several healthcare providers are relieved by this news. It’s no secret that a large segment of the healthcare industry simply wasn’t prepared for the move. For example, a KPMG survey conducted earlier this year indicated that 50 percent of health plans and providers had not yet evaluated how the new ICD-10 coding system would impact their systems and cash flow. To this contingent I say “congratulations.” Congratulations on getting yet another stay of execution on a coding system the rest of the free world moved to eons ago. Congratulations on not having to face this particular change in 2014 — even if it would mean better clinical documentation, patient care, and outcomes. Congratulations on avoiding a much needed and long overdue area of progress in the U.S. healthcare system.
In case you couldn’t discern my stance from these comments, I’m not a fan of another ICD-10 delay. On the contrary, I think it stinks. There are countless reasons why, but I’ll try to sum up my feelings in a few paragraphs.
ICD-9 Doesn’t Cut It
The current ICD-9 code set was developed in the 1970s. It fails to incorporate categories for modern day health threats like bioterrorism. Heck, it doesn’t even provide the basic granularity that allows an injury on the right side of the body to be distinguished from one on the left side. But hey, providers know how to get reimbursed based on ICD-9 codes, so it has remained the standard code set for American medicine long past its shelf life.
However, this was supposed to be the year that changed all that. After repeated attempts to move to ICD-10 were thwarted (some dating back to the 1990s), a supposedly firm October 1, 2014 deadline was set. Key industry leaders like former ONC chief Dr. Farzad Mostashari and CMS administrator Marilyn Tavenner said in no uncertain terms that there would be no more ICD-10 delays.
The healthcare industry finally seemed to take notice. While some payers and providers resisted change, others made the infrastructure and process changes necessary to make the transition. We were on the cusp of a new era of healthcare documentation. We were in the 11th hour … then Congress stepped in and transported us back to 2012.
The most troubling part is most members of Congress seem ignorant of the repercussions. The ICD-10 delay inclusion in the SGR bill wasn’t even mentioned during the Senate vote on Monday. Sadly, (as mentioned in an InformationWeek article by David F Carr) it seems like the ICD-10 provision seems to have been thrown into the bill as a “consolation prize” for the physicians lobby, after efforts to permanently repeal the SGR formula failed.
ICD-10 Delay Punishes Prepared Providers
So here we are … delayed again. However, this delay stings more than all the others. Unlike in previous years where the overwhelming majority of the industry was unprepared for an ICD-10 transition, this time a large number of providers were ready. This year’s delay essentially punishes those providers that invested the time, energy, and money necessary to make the switch in October.
These investments are not insignificant. According to AHIMA, healthcare payers and providers have already invested millions to prepare for ICD-10. The association also estimates the additional year delay will cost the industry another $1 billion to $6.6 billion. I’m not sure how accurate these figures are (it strikes me as a wildly broad range), but even on the low-end of the scale, this move is clearly wasteful and flies in the face of the efforts being made to control healthcare costs.
There are those who will argue that the money already invested in ICD-10 will not be wasted, but rather deferred. True, the infrastructure investments made in preparation for an October 2014 transition should still be viable in 2015 (That is, if the industry still implements ICD-10 and doesn’t jump directly to ICD-11). However, what about the training costs? Many providers subscribe to just-in-time training so that coders and physicians can take the new codes and documentation procedures they learn in the classroom and quickly apply them to actual transactions. With ICD-10 code sets now another year away from being the accepted standard, the real word scenarios to apply new teachings will be hard to come by. In essence, much of the ICD-10 training done to date will be for naught (i.e. forgotten after a year of non-practice), and many providers will need to reinvest in training closer to the new 2015 deadline.
The latest ICD-10 delay is also particularly disheartening for the more than 25,000 students currently enrolled in HIM (health information management) associate and baccalaureate educational programs. These students have learned to code exclusively in ICD-10, with the understanding that ICD-9 codes would be phased out come October 2014. What are the graduates of these programs supposed to do with their skill sets between now and 2015? The delay definitely makes it difficult for these students to find gainful employment right out of school.
ICD-10 Delay Slows Healthcare Progress
To me, the most disappointing aspect of the ICD-10 delay is simply that it slows the progress of healthcare in the United States. Over the past several years, a ton of focus has been placed on reforming our healthcare system. For example, the HITECH Act and the Meaningful Use program have incentivized much needed adoption of health IT systems, and ACA aims to change the way providers are reimbursed. In my opinion, an ICD-10 delay ties a big anchor around these efforts. Think about it — more granular codes and clinical documentation are essential to driving ROI out of an EHR investment and effectively tracking patient populations. Likewise, ICD-10 codes provide the clarity necessary for accurate care coordination and outcomes-based reimbursement.
At the end of the day, patients are the biggest victims of the ICD-10 delay. Waiting another year to update the code set is another year patients are at risk of being improperly treated because of gaps, inconsistencies, or lack of detail in their health records. We should have moved beyond ICD-9 by this point. There’s no reason we couldn’t have made the change by this October. This delay was no longer a technological issue, but a political one. I hope I’m not writing a similar article at this time next year, but I won’t be too surprised if I am.