On April 1, President Obama signed the Protecting Access to Medicare Act of 2014 into law.
In addition to shielding physicians for one year from steep pay cuts under Medicare's sustainable growth rate and delaying enforcement of the two-midnight rule for six months, the law stops HHS from requiring healthcare providers to switch to ICD-10 before Oct. 1, 2015.
The delay has frustrated many industry stakeholders and healthcare providers who had invested considerable time and resources into preparing for the original go-live date of this October. Michael Lee, MD, director of clinical informatics at Newton, Mass.-based Atrius Health, says while he views implementing ICD-10 in the first place as a "really bad choice," delaying it at this point is another unwise decision. Dr. Lee says it's important to look at ICD-10 in the context of other projects on providers' plates right now, such as attesting to meaningful use.
"In an IT world, when you get six months from a go-live, you're 90 percent through with all your project work," he says. "It's not like a six-month warning gets you out of anything in terms of your work effort. If you delay it by any significant amount of time, it now changes all of your project planning across many disciplines."
Before the delay was announced, Atrius Health — an alliance of six nonprofit community-based physician groups and a home health and hospice agency — had already hired consultants, trained thousands of clinicians and done substantial software program and decision support work in preparation for the switch to ICD-10. Now, the organization's project plan for the next 24 months must be reset, which will include reassessing contracts with outside vendors and re-evaluating all implementation tools, among other tasks, Dr. Lee says.
"It's an unbelievable impact on our work," Dr. Lee says. "I think that the government is really underestimating the implementation complexity of all their programs right now."
Fletcher Lance, vice president and national healthcare leader at the global consulting firm North Highland, says larger providers who were already on track for a successful transition six months from now are now in a "bit of a no-man's land." He says his firm is advising clients to pause and assess their current work plans in light of the new implementation date. "Take a pause, evaluate where you are and kind of reload," he says. "I think that will help you not have a bunch of rework."
Additionally, he says healthcare providers should continue with certain preparation efforts that are "just good business practices," including striving for better denials management, general clinical documentation improvement and financial contract modeling for ICD-10. "You've probably got some training in process…software upgrades, testing, physician education," he says. "Those are probably activities in flight. Don't stop, go on and complete that. Psychologically, if you pull the Band-Aid off, that's tough on the staff."
Terrance Govender, MD, director in the healthcare practice at Navigant Consulting, agrees that providers shouldn't slam on the brakes when it comes to their ICD-10 preparation efforts, especially concerning physician training. "I suggest organizations stay on a solid path," he says. "Do not make any extended delays in implementation training."
However, the delay will likely have some detrimental effects on those training efforts. Dr. Govender says that although hospitals and health systems can mitigate the damage by continuing to stress the value of the transition, "we do lose a lot of credibility when these deadlines keep shifting." The transition was also delayed in 2012, and a second delay makes it difficult to convince physicians ICD-10 is an inevitable "train coming down the tracks."
"Very frequently, physicians turn around and tell us this is never going to happen, or this is never going to be implemented," Dr. Govender says.
Additionally, the delayed implementation date will also have a negative impact on providers' finances. Mr. Lance says although providers can probably stretch out and recalibrate their ICD-10 budgets, there will inevitably be some "leakage" in terms of planning and resource disruption. "Any time you lose momentum on any activity, there's some restart costs," he says.
Although it's hard to know the exact amount of money Atrius Health will lose because of the delay, Dr. Lee says it will certainly exceed $1 million. "I would expect that the cost would be easily that amount if this takes another year," he says. "I have to redo just about 90 percent of what I've done continuously for the next 18 months."
However, the delay might not dismay everyone. Some healthcare organizations — those that were far behind in their ICD-10 preparations — are likely "breathing a sigh of relief" about the delay, Dr. Govender says. According to a recent Fitch Ratings report, the deadline extension is a positive development for nonprofit hospitals because it will give payers more time to prepare. "While a majority of providers have made the substantial investment in technology and personnel to be ready for the transition, the readiness of both governmental and commercial payers to adequately process claims and payments in a timely manner has been questioned," Fitch stated in a news release.
Still, Dr. Govender says pushing back the deadline won't necessarily help those lagging behind, depending on the root of their trouble with the transition. "Are we dealing with cultures that are not aggressive enough or don't take ICD-10 seriously enough?" he says. "I only hope that's not the case."
Atrius Health's Dr. Lee also doesn't think the delay will help those who aren't ready. "Payers who have not put in the effort to get ready and hospitals that have not put in the effort now are not going to suddenly jump on the boat," he says.
In fact, he thinks the only action the government could take that would truly help anyone at this point would be scrapping the transition entirely. "The better choice at this time would be to take it completely off the table…and to actually re-evaluate the entire project," he says. "That would have been a good choice for the government."
More Articles on ICD-10:
ICD-10: The Epitome of U.S. Healthcare Dysfunction
Fitch: ICD-10 Delay Will Benefit Nonprofit Hospitals
4 Must-Read Stories on the ICD-10 Delay