Last month, the HHS announced it would delay the Oct. 1, 2013, ICD-10 compliance date for certain healthcare entities. When most people hear about a "delay," schools calling in short postponement of the school day due to fog or snow come to mind. However, instead of two hours of extra sleep, hospitals, physicians and other providers do not know when school — or the ICD-10 timeline — is scheduled to resume, and this has created some tension within the healthcare industry.
How the delay came about
One of the most outspoken critics of the ICD-10 transition has been the American Medical Association, which made a vow during its fall policy-making meeting that it would "work vigorously to stop implementation of ICD-10." The AMA ramped up its efforts publicly by sending letters to House Speaker John Boehner (R-Ohio) and HHS Secretary Kathleen Sebelius urging that the entire ICD-10 process be halted.
Eventually, HHS and CMS gave in after previously insisting there would be no delay and no grace period for the Oct. 1, 2013, deadline. It should be noted that this most recent postponement of ICD-10 was not the first. The original "go-live" date of ICD-10 was supposed to be Oct. 1, 2011, which was then pushed back to Oct. 1, 2013.
Paul Spencer, CPC, CPC-H, compliance officer for Fi-Med Management, says the verbiage in the government's most recent announcement needs to be analyzed. HHS said it would work through a formal rulemaking process to delay the compliance date, possibly setting up a scenario like Version 5010. In November, CMS said all HIPAA-covered hospitals, physicians and other providers would have to use Version 5010 by this past Jan. 1, but CMS would not initiate enforcement of the standards until March 31.
"It could be they mandate the use of ICD-10 by Oct. 1, 2013, but give providers three to six more months to comply," Mr. Spencer says. "That's just a guess based on the release, but with any government edict, it's always worth looking at the exact wording."
Additionally, the wording of the announcement could imply that "certain healthcare entities," such as physicians, may have a different compliance date than hospitals or other healthcare providers, which the College of Healthcare Information Management Executives has argued against. HHS and CMS are still re-examining the industry's pace toward ICD-10 and are expected to announce a new compliance date soon.
Should ICD-11 be the new focus?
By the time the United States is fully functioning with ICD-10 as the default diagnostic and procedural coding system, ICD-11 will be right around the corner.
Mr. Spencer first voiced his concern of converting to ICD-10 in 2008, when CMS was first making its proposed rules on ICD-10. At that point in time, ICD-10 had been around for roughly 15 years already. In his comments, he wrote that if "ICD-10 is adopted in 2011 for use in the United States, the American healthcare infrastructure, in roughly five years time, will be faced with exactly the predicament it now faces, namely the use of an outdated standard for disease and symptom reporting." Now, with this most recent delay and ICD-11 even closer, he says ICD-10 is beginning to look like "a bigger waste of time and money."
The World Health Organization, which publishes the International Classification of Diseases, expects to have the beta draft of ICD-11 out this May. During this process, WHO and other international healthcare stakeholders will make comments and proposals to refine ICD-11, and by May 2015, ICD-11 will be presented to the World Health Assembly.
After that, the United States would have to develop its own clinical modification version of ICD-11. Robert Tennant, senior policy advisor of MGMA-ACMPE, says the United States will start to develop its clinical modification version in 2015. He admits that all alternatives should be looked at when it comes to ICD-10 implementation, but he expects a U.S. version of ICD-11 would not be ready until several years after the WHO publishes their final draft.
Mr. Tennant adds that comparing the U.S. healthcare system to others that have successfully implemented ICD-10 — such as Australia, Canada and Germany — is not "comparing apples to apples" because their ICD-10 versions have between 13,000 and 22,000 codes, while the U.S. ICD-10-CM has roughly 68,000. Additionally, those countries have only implemented ICD-10 in the hospital setting, while the U.S. ICD-10 mandate includes both hospitals and physician practices.
Mr. Spencer says there are several competing priorities over ICD-10 right now, including accountable care organizations and bundled payments, but if the country is going to fall behind the world again when it comes to ICD, those priorities may have to be restructured. He also says the U.S. clinical modification may be an impediment to future coding initiatives.
"We have a prejudice against ICD-11 right now because we don't have an American clinical modification, and my strong sense is that we'd be better off moving to ICD-11," Mr. Spencer says. "Whenever [the WHO] works on a draft copy of ICD, the U.S. will always have to do a clinical modification. But it may not be to the liking of the powers that be in the U.S. health insurance companies. If we were going to be honest players on the world stage, we'd all be on the same data standards."
What to do from here
How U.S. hospitals, health systems and others will treat the gradual adoption of ICD-11 on a worldwide scale remains to be seen. In the meantime, Mr. Tennant argues that ICD-10 still needs more research before a solid, permanent timeline can be affirmed. From June 30, 2003, through August 5, 2003, 169 AHIMA-certified coders coded 6,177 medical records using ICD-10 — one of the few documented tests for the functionality of ICD-10.
"What we don't want is to blindly move forward without evidence of ICD-10's impact," Mr. Tennant says. "We can't endorse, moving forward, groping in the dark and hoping there will be a [return on investment] at the end of the tunnel. This is too expensive of a change without having a clear sense of what the impact will be."
Judith Holloway, RHIA, CCS, CCS-P, quality director of health information services at HFS Consultants, says the specificity of ICD-10 is one of those intrinsic impacts that can be seen immediately by the healthcare system at-large. ICD-10 could also directly alter the way healthcare providers analyze medical data to improve healthcare in the future. "ICD-10-CM and -PCS offer greater detail and increased ability to accommodate new technologies and procedures," Ms. Holloway says. "The codes have the potential to provide better data for evaluating and improving the quality of patient care. For example, data captured by the code sets could be used in more meaningful ways to better understand complications, design clinically robust algorithms and track care outcomes."
For hospitals and physician practices that are unsure what steps to take from here, Don May, vice president of policy for the American Hospital Association, says providers can judge where they are at from four basic phases: organizing effort, conducting a planning and impact analysis, performing the actual ICD-10 implementation and evaluating the system once the ICD-10 implementation is complete. He says most hospitals are in the first two phases, mostly due to the plethora of competing priorities from healthcare reform and health information technology requirements. "We want to make sure the transition goes as smoothly as possible," Mr. May says. "There's a whole lot going on right now: the implementation of Version 5010, meaningful use and others. We're trying to watch all these things as they happen."
However, regardless of the delay, healthcare providers cannot push off ICD-10 completely and "sleep" for the remainder of the day. HHS and CMS have still indicated there will be a new timeline set for ICD-10. It's just a matter of what that new timeline will be. "As anyone who has been involved with the conversion can attest, it is indeed a daunting project, requiring painstaking attention to detail, diligence in communication and an ongoing focus on virtually every interconnected hospital system and process," says Kerry Stark, senior director of revenue cycle management for VHA. "Clinicians, administrators — everyone is involved, from physicians and nurses to coders and the C-suite.
"Healthcare's smartest systems will make good use of any extra time and not be lulled into a false sense of complacency," he adds. "Providers must remember: The potential compliance date change should prove to be only a delay. ICD-10 is not going away and is an important part of the future of our healthcare system moving forward."
How the delay came about
One of the most outspoken critics of the ICD-10 transition has been the American Medical Association, which made a vow during its fall policy-making meeting that it would "work vigorously to stop implementation of ICD-10." The AMA ramped up its efforts publicly by sending letters to House Speaker John Boehner (R-Ohio) and HHS Secretary Kathleen Sebelius urging that the entire ICD-10 process be halted.
Eventually, HHS and CMS gave in after previously insisting there would be no delay and no grace period for the Oct. 1, 2013, deadline. It should be noted that this most recent postponement of ICD-10 was not the first. The original "go-live" date of ICD-10 was supposed to be Oct. 1, 2011, which was then pushed back to Oct. 1, 2013.
Paul Spencer, CPC, CPC-H, compliance officer for Fi-Med Management, says the verbiage in the government's most recent announcement needs to be analyzed. HHS said it would work through a formal rulemaking process to delay the compliance date, possibly setting up a scenario like Version 5010. In November, CMS said all HIPAA-covered hospitals, physicians and other providers would have to use Version 5010 by this past Jan. 1, but CMS would not initiate enforcement of the standards until March 31.
"It could be they mandate the use of ICD-10 by Oct. 1, 2013, but give providers three to six more months to comply," Mr. Spencer says. "That's just a guess based on the release, but with any government edict, it's always worth looking at the exact wording."
Additionally, the wording of the announcement could imply that "certain healthcare entities," such as physicians, may have a different compliance date than hospitals or other healthcare providers, which the College of Healthcare Information Management Executives has argued against. HHS and CMS are still re-examining the industry's pace toward ICD-10 and are expected to announce a new compliance date soon.
Should ICD-11 be the new focus?
By the time the United States is fully functioning with ICD-10 as the default diagnostic and procedural coding system, ICD-11 will be right around the corner.
Mr. Spencer first voiced his concern of converting to ICD-10 in 2008, when CMS was first making its proposed rules on ICD-10. At that point in time, ICD-10 had been around for roughly 15 years already. In his comments, he wrote that if "ICD-10 is adopted in 2011 for use in the United States, the American healthcare infrastructure, in roughly five years time, will be faced with exactly the predicament it now faces, namely the use of an outdated standard for disease and symptom reporting." Now, with this most recent delay and ICD-11 even closer, he says ICD-10 is beginning to look like "a bigger waste of time and money."
The World Health Organization, which publishes the International Classification of Diseases, expects to have the beta draft of ICD-11 out this May. During this process, WHO and other international healthcare stakeholders will make comments and proposals to refine ICD-11, and by May 2015, ICD-11 will be presented to the World Health Assembly.
After that, the United States would have to develop its own clinical modification version of ICD-11. Robert Tennant, senior policy advisor of MGMA-ACMPE, says the United States will start to develop its clinical modification version in 2015. He admits that all alternatives should be looked at when it comes to ICD-10 implementation, but he expects a U.S. version of ICD-11 would not be ready until several years after the WHO publishes their final draft.
Mr. Tennant adds that comparing the U.S. healthcare system to others that have successfully implemented ICD-10 — such as Australia, Canada and Germany — is not "comparing apples to apples" because their ICD-10 versions have between 13,000 and 22,000 codes, while the U.S. ICD-10-CM has roughly 68,000. Additionally, those countries have only implemented ICD-10 in the hospital setting, while the U.S. ICD-10 mandate includes both hospitals and physician practices.
Mr. Spencer says there are several competing priorities over ICD-10 right now, including accountable care organizations and bundled payments, but if the country is going to fall behind the world again when it comes to ICD, those priorities may have to be restructured. He also says the U.S. clinical modification may be an impediment to future coding initiatives.
"We have a prejudice against ICD-11 right now because we don't have an American clinical modification, and my strong sense is that we'd be better off moving to ICD-11," Mr. Spencer says. "Whenever [the WHO] works on a draft copy of ICD, the U.S. will always have to do a clinical modification. But it may not be to the liking of the powers that be in the U.S. health insurance companies. If we were going to be honest players on the world stage, we'd all be on the same data standards."
What to do from here
How U.S. hospitals, health systems and others will treat the gradual adoption of ICD-11 on a worldwide scale remains to be seen. In the meantime, Mr. Tennant argues that ICD-10 still needs more research before a solid, permanent timeline can be affirmed. From June 30, 2003, through August 5, 2003, 169 AHIMA-certified coders coded 6,177 medical records using ICD-10 — one of the few documented tests for the functionality of ICD-10.
"What we don't want is to blindly move forward without evidence of ICD-10's impact," Mr. Tennant says. "We can't endorse, moving forward, groping in the dark and hoping there will be a [return on investment] at the end of the tunnel. This is too expensive of a change without having a clear sense of what the impact will be."
Judith Holloway, RHIA, CCS, CCS-P, quality director of health information services at HFS Consultants, says the specificity of ICD-10 is one of those intrinsic impacts that can be seen immediately by the healthcare system at-large. ICD-10 could also directly alter the way healthcare providers analyze medical data to improve healthcare in the future. "ICD-10-CM and -PCS offer greater detail and increased ability to accommodate new technologies and procedures," Ms. Holloway says. "The codes have the potential to provide better data for evaluating and improving the quality of patient care. For example, data captured by the code sets could be used in more meaningful ways to better understand complications, design clinically robust algorithms and track care outcomes."
For hospitals and physician practices that are unsure what steps to take from here, Don May, vice president of policy for the American Hospital Association, says providers can judge where they are at from four basic phases: organizing effort, conducting a planning and impact analysis, performing the actual ICD-10 implementation and evaluating the system once the ICD-10 implementation is complete. He says most hospitals are in the first two phases, mostly due to the plethora of competing priorities from healthcare reform and health information technology requirements. "We want to make sure the transition goes as smoothly as possible," Mr. May says. "There's a whole lot going on right now: the implementation of Version 5010, meaningful use and others. We're trying to watch all these things as they happen."
However, regardless of the delay, healthcare providers cannot push off ICD-10 completely and "sleep" for the remainder of the day. HHS and CMS have still indicated there will be a new timeline set for ICD-10. It's just a matter of what that new timeline will be. "As anyone who has been involved with the conversion can attest, it is indeed a daunting project, requiring painstaking attention to detail, diligence in communication and an ongoing focus on virtually every interconnected hospital system and process," says Kerry Stark, senior director of revenue cycle management for VHA. "Clinicians, administrators — everyone is involved, from physicians and nurses to coders and the C-suite.
"Healthcare's smartest systems will make good use of any extra time and not be lulled into a false sense of complacency," he adds. "Providers must remember: The potential compliance date change should prove to be only a delay. ICD-10 is not going away and is an important part of the future of our healthcare system moving forward."
More Articles on ICD-10:
ICD-10 Specialists Respond to Deadline Delay
HHS to Delay ICD-10 Compliance Date
5 Areas of Risk in the ICD-10 Conversion