HHS proposes rule to require ICD-10-CM by 2011

On Friday, August 15, the Department of Health and Human Services issued a notice of proposed rule making that would require the adoption of ICD-10-CM for the purposes of diagnosis coding. They proposed a date of October 1, 2011 for the switch.

The proposed rule is available here (warning: pdf).

The proposal recommends an "all at once" change over. There would be no phased approach, or time period where both ICD-9-CM and ICD-10-CM are used concurrently.

The proposed rule would affect all "covered entities" under the Health Insurance Portability and Accountability Act. Determining whether a health care provider, physician, insurance plan, or claims "clearinghouse" is a covered entity is a bit complex (see the 10pp pdf file the Centers for Medicare and Medicaid Services provide for making the determination). However, the bottom line is that the vast majority of physicians, physician practices, hospitals, health plans, and claims clearinghouses are covered and thus affected.

A great deal of the proposal is made up of a detailed analysis of the costs and benefits of the switch. The proposal itself does not provide a total cost, but one can easily add up the costs in Table 10. The cost estimate ranges from $849 million to $3 billion, with a "primary estimate" of $1.64 billion.

We'll have a lot to say about various myths that people cite in favor of a switch to ICD-10-CM in coming posts. However, suffice it to say that many of these myths are reproduced in this proposal as arguments in favor of ICD-10-CM. We'll expose these myths.

All in all, the notice of proposed rule making is a colossal mistake. Again, if we will expend billions of dollars to change our diagnosis coding system, we ought to switch to a better system than ICD-10-CM.