ICD-10-CM and Windows ME: A Switching Analogy

Much of the lack of resistance to the switch to ICD-10-CM is based on the presumption that since it is the next "version", it simply must be better. Proponents deride the arguments against the switch as being analogous to the question "MS-DOS works fine, why Windows?"

However, a better operating-system analogy would be "Windows 98 works fine, why Windows ME?"

As those who upgraded to Windows ME can attest, the upgrade was a complete disaster. PC World rated Windows ME as the fourth worst tech product of all time.

Analogously, ICD-10-CM is the last upgrade for the archaic, "statistical classification" architecture of terminologies. ICD-11 will use modern approaches to terminology.

In this sense ICD-10-CM is very much like Windows ME, in that Windows ME was the last MS-DOS based Microsoft OS before Microsoft converted its home OS to the newer, Windows NT architecture.

How ironic.

As naysayers against ICD-10-CM, we are saying that we should skip ICD-10-CM, which is the Windows ME of disease classification. It is the proponents of ICD-10-CM who are arguing for the perpetuation of ancient technology, not the naysayers.

The cost of the switch, briefly revisited

Prior efforts to estimate of the cost of switching from ICD-9-CM to ICD-10-CM compared the cost to that of Y2K remediation. In a post last year, we also highlighted the comparison.

The American Hospital Association estimates that the cost of Y2K was $8 billion for hospitals. Compare that to the Health and Human Services (HHS) estimate for switching to ICD-10-CM of $1.6 billion.

Now comes the experience of someone who lived through Y2K and now is preparing his hospital for the government-mandated switch.

Stanley Padfield, system director for health information management at four-hospital Lee Memorial Health System, Cape Coral, Fla, considers the cost of the switch to be higher than that of Y2K remediation.

An article describing Padfield's experience notes:

Padfield says tackling the ICD-10 challenge will prove more difficult than Y2K “because there are a lot more variables involved.” Plus, providers that fail to adequately prepare risk not getting paid promptly by Medicare and other payers.

So, the early experience is already that the ICD-10-CM switch will cost hospitals more than the $8 billion they spent on Y2K. Which dwarfs the HHS low-ball figure of $1.6 billion for the entire health care system to switch.

Even the optimistic RAND report that analyzed the cost of the switch could not come up with more than $7.7 billion in benefits to the switch.

So the early signs are that the costs of the ICD-10-CM switch to the health care system will far exceed the benefits.

Background on disease classification and coding

The Encyclopedia of Public Health on Answers.com has two, concise articles on classification of disease and its history.

For a concise overview on the general task of classifying diseases and the reasons for it, see the Classification of Disease entry.

For a history of disease classification and the International Statistical Classification of Diseases and Related Health Problems (now the official name for ICD, including ICD-10), see this article.

"Meaningful Use" criteria require problem lists in ICD-9 or SNOMED

As we discussed in previous posts here and here, the "stimulus bill" passed by Congress earlier this year increases Medicare and Medicaid payments to physicians and hospitals who are "meaningful users" of electronic medical records (EMRs) in coming years.

The linchpin to the payments is the definition of "meaningful use", which the law mandates that the Department of Health and Human Services (HHS) define. The law also mandated the formation of the Healthcare Information Technology (HIT) Policy committee, and it is this committee that is currently conducting hearings into what the criteria for "meaningful use" should be. Ultimately, HHS will define meaningful use through a rulemaking process similar to the one that led to the mandate to switch to ICD-10-CM.

Well, the latest "matrix" (warning: pdf) of meaningful use criteria stipulate that the EMR must maintain problem lists in either ICD-9 or SNOMED.

We think they are both terrible choices. Problem lists maintained in either system are not likely to be very meaningful at all.

Doctors: ICD-10 Switch Inhibits "Meaningful Use" of EMRs

For a brief introduction to federal incentives for adoption of electronic medical records (EMRs), see yesterday's post.

In response to a request for comments on proposed rules for meaningful use, over 80 physician organizations joined forces behind a letter to the Office of the National Coordinator for Health Information Technology (ONCHIT). This letter outlines the unanimous opinion of these organizations on what the "meaningful use" criteria for EMRs should be.

The 80 organizations include the American Medical Association, the American Academy of Family Physicians, the American College of Obstetricians and Gynecologists, the American College of Radiology, the American College of Surgeons, the American College of Physicians, and numerous state medical societies.

In an attachment to the letter, these doctors' organizations note that in setting the timing of EMR implementation, ONCHIT should ...Factor in the Implementation of Version 5010, ICD-10, and Other Related Compliance Deadlines.

The attachment goes on to say:

The health care industry, including physicians, will be migrating to the next version of HIPAA electronic transactions standards,Version 5010, by January 1, 2012. Moreover, the transition from using ICD-9 to ICD-10 codes must occur by October 1, 2013 which is expected to be an even more complex undertaking than the adoption of the first version of HIPAA standards (4010) and the transition to use of the National Provider Identifier (NPI). The implementation timeframe must factor in vendor, physician, and other health care partner readiness for all of these significant transitions that will occur simultaneously with the incorporation of HHS’ recommended standards for qualifying EHRs.

Which ultimately means that physicians, in addition to hospitals, expect the switch to ICD-10-CM to slow them down significantly with respect to becoming "meaningful users" of EMRs.

Hospitals: ICD-10 Switch Inhibits "Meaningful Use" of EMRs

The "stimulus package"--more formally known as the American Recovery and Reinvestment Act of 2009--promises doctors and hospitals increased reimbursement from Medicare and Medicaid if they become "meaningful users" of electronic medical records (EMRs). Of course, the Act leaves open the definition of meaningful use, leading to yet another rulemaking process similar to the one that produced the mandate to switch to ICD-10-CM.

In its comments to the Office of the National Coordinator for Health Information Technology (ONCHIT), the American Hospital Association (AHA) correctly recognizes that the switch to ICD-10-CM will drain away resources from their efforts to become meaningful users of EMRs. In response, the AHA says that ONCHIT should slow down and lighten the criteria for "meaningful use."

The AHA comments (warning: pdf) say:

Staging the requirements and use levels in the definition also should recognize other HIT initiatives already underway and the likely vendor and workforce constraints hospitals may face. Hospitals are required to move to the new X12 Version of 5010 HIPAA standards in 2010 and ICD-10 in 2013. The AHA also is concerned that vendors will not be able to improve, test, implement and support HIT systems in hospitals nationwide due to the increased and simultaneous demand for HIT services and products. Vendor and hospital IT workforce capacity constraints should be considered as well.

In other words, the switch to ICD-10-CM will pull resources away from hospitals' ability to achieve meaningful use of EMRs.

A "monstrous task", "like a heart transplant."

These are the words of those who are starting to investigate the true cost and effort of switching to ICD-10-CM, as quoted in an article about the Healthcare Financial Management Association's annual Healthcare Finance Conference.

Orlando Health has found that the switch will affect 90% of all of its information systems. Integris Health of Oklahoma City has found that the switch will require "changes in data flow," "broad testing," and "intensive staff education".

The American Health Information Management Association (AHIMA), cheerleader for the switch to ICD-10-CM, recommends that you "establish a multi-disciplinary planning team involving all departments" now as a first step for making the transition.

If we're going to expend such resources to switch, why are we adopting a system whose core structure and framework is from the era of punchcards and paper charts?

In other words, if we're going to do a heart transplant, shouldn't we put in a good heart?