Doctors' organizations aligned against the switch

Led by the American Medical Association, 82 doctors' organizations have written a letter (PDF) to the Secretary of Health and Human Services opposing the switch to ICD-10-CM.  The letter was signed by 42 state medical societies and 40 specialty-specific medical societies, including the largest states (California, Texas, Florida) and most prestigious specialty societies (American College of Cardiology, American Academy of Ophthalmology, and the American Academy of Family Physicians).

The reason physicians oppose the switch is that it provides no direct benefit to patient care and the switch is only one of many regulatory burdens recently imposed by the federal government and physicians are having trouble managing them all at once.  ICD-10 is an administrative code set that supports payment for health care: it is on the "back end" and thus does not impact patient care at all, let alone favorably.  The burden of the switch is thus a net negative in doctors caring for patients, because it is costly and distracting.  The other regulatory burdens the letter calls out are (1) implementation of electronic health records to meet "meaningful use" criteria, (2) electronic prescribing, and (3) mandatory participation in the Physician Quality Reporting System (PQRS) and value-based modifier programs.

Physicians are correct.  The cost of the switch outweighs its benefits and it ought to be halted.

Ill-formed ICD-10-CM codes causing coding problems, as predicted nearly 13 years ago

Dr. Vergil Slee and his co-authors predicted in their 2000 book The Endangered Medical Record that the use of capital 'I' and lower-case 'o' in ICD-10-CM codes would cause confusion (with the numeral '1' and the numeral '0', respectively).

That prediction has come true.  Annie Boynton, director of provider regulatory compliance (ICD-10) communication, adoption and training for UnitedHealth Group, says that problems such as distinguishing between the letter “o” and the number zero and “1” and “I” result in incorrect and partial coding.

That and other technical issues with ICD-10-CM make it an antiquated system to which we should not switch!

Doctors continue fight against misguided ICD-10-CM switch

The American Medical Association will continue its fight against the switch to ICD-10-CM.  The switch is currently mandated by the federal government to occur on October 1, 2014.  The AMA will evaluate the possibility of switching directly to ICD-11 in 2017.

HHS will delay ICD-10-CM till October 1, 2014

A story in Health Data Management indicates that the Department of Health and Human Services will issue a final rule that delays the switch to ICD-10-CM till October 1, 2014.  The original switch date was October 1, 2013.

The reason for the switch is nothing more than too much regulation all at once.  Either ICD-10-CM or meaningful use of electronic health records (another HHS mandate implemented by means of a regulatory rule) had to give way.  We thought that ICD-10-CM had more sway, but were pleasantly surprised that the archaic code set took a back seat.

We even had some hope that HHS would still see the light and scrap ICD-10-CM altogether.  But alas.

Doctors advocate delays and halts to ICD-10-CM switch

The American Medical Association, in response to the proposed rule (PDF) to delay the ICD-10-CM switch by one year, recommends (PDF) instead that the switch be delayed two years.  The proposed rule would delay the switch to October 1, 2014, but the AMA requests instead that the government delay the switch to October 1, 2015.

The AMA letter states:


A two-year delay of the compliance deadline for ICD-10 is a necessary first step.  This postponement period would provide CMS with adequate time to pursue a much needed cost-benefit analysis of the full 
ICD-10 move that covers the administrative and financial impact of the ICD-10 move on physician 
practices.  During this time, we also urge CMS to institute a process to engage all relevant 
stakeholders including physicians to assess whether an alternative code set approach is more 
appropriate than the full implementation of ICD-10.  


Meanwhile, the Texas Medical Association has called (PDF) for a complete halt to the switch to ICD-10-CM.  This letter states:


The adoption of a standard that is acknowledged to be on the brink of obsolescence will not bring a 
sufficient benefit in light of the cost, disruption, and man-hours that must be dedicated to ICD-10 
implementation.  TMA argues that the savings and benefits of adopting ICD-11 should be 
researched by the Department.


There is much wisdom in both letters.  The switch to ICD-10-CM will not have the intended benefits, because at a minimum, the costs well exceed the estimates given by various reports and studies and the rule mandating the switch in the first place.

Furthermore, ICD-10-CM is not just on the brink of obsolescence, it is well over the brink.  The basic structure dates back to ICD-7 and 8, which were developed 55 and 45 years agao, respectively.

It is time to stop the switch.

The myth of manual ICD-10-CM code assignment

In a previous post, we took issue with the final rule mandating the switch to ICD-10-CM, because the rule argues that certain alternatives to ICD-10-CM are impractical because they require computer software to assist in assigning diagnosis codes to patient records.

The implication then is that ICD-10-CM does not require computer software to assist in the assignment of diagnosis codes.  And thus that manual assignment of ICD-10-CM diagnosis codes is substantially more feasible.

Now, a survey reveals that nearly half of healthcare providers plan to buy "computer assisted coding" (CAC) software to help them with the switch to ICD-10-CM.  A previous survey about the switch reveals that only 50% of healthcare providers have even completed an "impact assessment" for their transition to ICD-10-CM.  It seems unlikely that those who are well behind the curve on the switch are the ones considering CAC software, so it is likely that everyone who is far along in the transition is considering it (50% have completed impact assessment and 50% are considering CAC software).

And thus we see that healthcare providers in large numbers disagree with the Department of Health and Human services, that manual coding of ICD-10-CM is feasible.

And thus another argument against alternatives to ICD-10-CM falls even further.

HHS proposes one-year delay to switch

The Department of Health and Human Services (HHS) has proposed a one-year delay in the switch to ICD-10-CM.  The compliance date would move from October 1, 2013 to October 1, 2014.

The move is one of several proposals HHS is making as part of a notice of proposed rule making here (warning: PDF).  Other rules include implementation of a national health insurance plan identifier.

HHS also considered (1) not changing the compliance date, (2) changing the compliance date instead to October 1, 2015, and (3) skipping ICD-10-CM altogether and waiting for ICD-11.