The death of the October 2014 implementation date for ICD-10 unfolded faster than the plot of a 30-minute sitcom. It started in the House of Representatives on a Wednesday when a provision to delay ICD-10 was quietly attached to bill H.R. 4302, also known as the SGR “doc fix” bill, and it was all over by the following Tuesday when President Obama signed the bill into law. If you blinked, you missed all the action.
Hospitals, payers, providers, and vendors have all invested millions of dollars and countless hours over the past several years getting ready for the transition, and then without notice someone moved the finish line – to October 1, 2015 maybe? Those hospitals who prepared early feel like they are paying a penalty for acting in good faith, while those who procrastinated are feeling vindicated and hopeful ICD-10 will never happen.
This week I heard from many customers who expressed feelings that ranged from shock to disappointment to anger. One customer, in the midst of a large computer-assisted coding implementation, sent an email that said, “The government may delay, but we will not delay.”
Another customer, a vice president of revenue cycle, called to discuss the impact on his organization, which had been very proactive in its ICD-10 implementation. The delay will definitely increase their transition costs, he said, but his concern went beyond the financial impact to the human side of the delay. This revenue cycle executive’s hospital system had funded tuition at a local school to train additional ICD-10 coders and he wondered about the real and immediate impact on students. Now there would be no jobs and no demand for their skills in the near term because the school’s curriculum focused solely on ICD-10 with no instruction in ICD-9 coding.
So where do we go from here? How do we make productive use of the delay and still drive to the future? I believe there are three steps we can take right now:
1. Remember and evangelize the importance of ICD-10 to realize the vision of healthcare reform: better outcomes at lower costs.
We’ve used ICD-9 codes in this country for 35 years. The rest of the world adopted ICD-10 codes more than a decade ago. ICD-10 codes are extremely precise, while ICD-9 codes lack significant detail. With ICD-9, there’s only so much information that is captured with each code. This precision and detail is important to understanding how good care happens and where we can reduce costs.
As an example, let’s look at ICD-9 code 996.1 (Mechanical complication of other vascular device, implant and graft). This code contains no information on the type of surgical complication (i.e., breakdown, displacement, leakage, etc.) and no information on the type of device, implant, or graft (aortic graft, dialysis catheter, arteriovenous shunt, counter pulsation balloon, etc.).
In ICD-10, full detail on the type of surgical complication and device, implant, or graft is provided. With the emphasis on linking quality and payment, and the move to value-based purchasing, it is easy to see why this level of detail is critical to delivering better outcomes at lower costs.
2. Stay focused. Test to protect momentum
Sounds simple, but take advantage of the delay to test systems and applications. Model payments with payers to make sure they can process ICD-10 coded claims. A clear focus on testing and feedback will mitigate any risk for the future and ensure that your investment in people and systems stays fresh.
In addition, keep your organization focused on key behaviors, such as clinical documentation improvement. It is essential for ICD-10 coding, but also benefits your organization under ICD-9, resulting in more accurate quality reporting and reimbursement.
If you are using a computer-assisted coding tool, continue to do some coding in ICD-10. It will keep your coders’ ICD-10 skills current and will also add to the body of ICD-10 coded documents needed to tune NLP engines for greater precision and recall.
3. Call on CMS to clarify and solidify the new implementation date as October 1, 2015.
Last but not least, we should all reach out to CMS and press for clarification and a decision on the implementation date. The language in H.R. Bill 4302 is unclear, stating that implementation is not to occur before October 2015. To move forward with confidence, protect current investments, and maintain momentum, a definitive date is essential.
It is disappointing that ICD-10 was delayed after so much effort, good will and investment by all participants in the healthcare industry, but it would be even more unfortunate if we are diverted by the siren’s song of “wait for ICD-11.” The regulatory process involved in adopting a new coding standard takes years (20 years in the case of ICD-10). Can we afford to continue delaying access to the critical information that is missing from ICD-9 codes today? The rich data of ICD-10 will both lower costs and save lives. As an industry, let’s lead the way to this better future now.
JaeLynn Williams is Senior Vice President of Sales, Marketing, and Client Operations for 3M Health Information Systems.