Picture this: a large group of would-be travelers, all of their worldly possessions packed into parcels and piled high atop rust-speckled jalopies, "Beverly Hillbillies"-style, gather in a large cluster in the middle of a field somewhere in New England. Citing excess population density, the government has ordered them to move west, all the way across the country to Californ-I-A. With the mandatory deadline for arrival rapidly approaching, they have yet to embark on the long journey.
Many of these folks had long assumed that if they simply ignored the mandate, the government would eventually back down, canceling the move order altogether or at the very least extending the deadline. Too late they have come to the disconcerting realization that no delay nor reprieve is coming, and the consequences of a failure to comply could be disastrous.
Eying their rickety conveyances, members of the group raise new concerns: the likelihood of flat tires, breakdowns or accidents and the resulting costly repairs and delays, as well as the relative unavailability of spare parts and repair facilities along the way. Winter is coming; the Rockies may well be impassable until spring!
Nearby, a brand-new 747 Dreamliner jumbo jet sits sparkling at the end of a long runway, its engines cycling up, boarding stairs in place and awaiting passengers. A small number of passengers sit comfortably aboard, peering perplexedly out the windows at the travelers and their jalopies. A jauntily dressed flight attendant jogs across the field and squeezes into the huddle.
“Um… folks? We’re about ready to take off, and we still have plenty of room on board — no charge. We can have you in California in six hours. Our in-flight movie is Disney’s "Frozen," and we’re serving a choice of chicken or pasta, with a wide selection of free beverages…”
Some of the travelers spare him a quick look, or glance fleetingly over their shoulders at the gleaming jumbo jet. But they quickly return to their anxious conversation. “It isn’t fair! We’ll never make it all the way across the country in these old rust-buckets!” “Let’s send another letter to Washington. Maybe they’ll back down and let us stay after all…”
The flight attendant shrugs and walks back toward the jet, shaking his head in puzzled resignation. The jet speeds down the runway and into the sky, leaving the cluster of travelers behind to their frustrations.
Earlier this month, the American Medical Association sent a letter to HHS Sec. Kathleen Sebelius calling for repeal — or at the very least another delay — of ICD-10, currently slated for implementation Oct. 1 of this year. Citing a recent study, the AMA asserts the cost of implementing ICD-10 for a small medical practice could run to nearly a quarter of a million dollars, jeopardizing patient care and even practices’ continued financial viability. This “unfunded mandate” will impede other important objectives, such as the adoption of advanced health IT and the transition to value-based models of care, according to the AMA. If ICD-10 must be implemented, the AMA argues, then physicians will require at least a two-year “implementation period,” during which there should be no effective penalty for noncompliance.
This reasoning is compelling, but it assumes that the nation’s physicians are all driving the technological equivalent of those rusted-out jalopies, and ignores the health IT Dreamliner revving up its engines on the nearby tarmac.
Here are some facts:
- Last year, athenahealth, the company for which I work, issued an unqualified ICD-10 readiness guarantee. Our clients will be ICD-10 compliant Oct. 1, or they won’t pay for our services. Months later, we are the only health IT vendor to issue such a guarantee (which likely explains the AMA’s continued trepidation).
- ICD-10 readiness will not cost athenahealth’s clients a quarter of a million dollars. It won’t cost our clients a single, solitary dollar. Because we operate on a cloud platform, every single one of our clients will be upgraded to the same ICD-10 compliant version of our software Oct. 1, at no additional cost.
- ICD-10 compliance will not add to our clients’ administrative burdens, and it will not impede either care delivery nor innovation (theirs or ours). They will not need a two-year implementation period. They will not even need a two-day implementation period.
Other cloud-based vendors have the same capabilities, and will likely see the same results. Of course the AMA does not only represent physicians on cloud-based platforms. An awful lot of its members are saddled with health IT vendors who have likely already made it clear that they will not be ready for Oct. 1—and that readiness, when it comes, will carry a hefty price tag. "Pile in the back of the pickup! It is going to be a long, bumpy ride!"
The point isn’t that the AMA should push physicians toward the cloud; that isn’t its role. But neither should the AMA nor the policymakers it hopes to influence ignore the cloud’s existence, or its implications for solving the problem at issue.
As has too often been the case with meaningful use policy, there is a danger with ICD-10 that in addressing the legitimate concerns of care providers whose health IT vendors are coming up short, policymakers will sacrifice legitimate policy goals to accommodate technological laggards—ultimately causing further harm to the providers (and their patients) whose interests groups like the AMA are trying to protect.
Whether the issue is ICD-10, meaningful use, or the slow transition from fee-for-service to value-based models of care, the goal of sound public policy should be to get more care providers over the finish line, at lower cost — not to slow the progress of technological innovators to give technological laggards more time to charge their clients exorbitant fees for inferior services.
Providers who have made the move to cloud-based platforms are sitting aboard the ICD-10 Dreamliner, preparing for take-off, with plenty of room for company. At the just-completed HIMSS conference in Orlando, CMS Administrator Marilyn Tavenner announced that there will be no further delays of ICD-10, suggesting that policymakers at HHS are finally resisting calls to head out into the field to jump-start the jalopies, and instead moving at last to help fill those empty seats.
Dan Haley is athenahealth’s vice president of government and regulatory affairs, responsible for all aspects of the company’s interactions with government and government officials at the federal, state, and local levels. Prior to joining athenahealth, Mr. Haley was a partner at a global law firm, where his practice focused on government and regulatory affairs and complex commercial litigation. He has held senior positions in a number of statewide political campaigns, served as general counsel to Sen. Scott Brown’s (R-Mass.) reelection committee, assistant Chief of Staff to Gov. Mitt Romney (R-Mass.), and worked at a number of national political committees. Dan is a graduate of Middlebury College and Harvard Law School.