Oklahoma Senator files bill to stop the switch

Sen. Tom Coburn (Oklahoma) has introduced in the U.S. Senate a version of the Cutting Costly Codes Act of 2013.  This bill would block HHS from implementing the ICD-10-CM on October 1, 2014.  This action follows the filing of a similar bill in the U.S. House by a Texas congressman. 

Many of Dr. Coburn's physician colleagues in the U.S. Senate have signed on as co-sponsors of the bill.

They are correct. We should stop the switch.

Texas congressman introduces bill to stop the Switch

Texas Congressman Ted Poe has introduced the "Cutting Costly Codes Act of 2013" (HR 1701), which would put a halt to the switch to ICD-10-CM.  It is a good idea, and merits passage and signature by the President.

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.