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.

ICD-10 Precursor Delayed Again

The Centers for Medicare and Medicaid Services (CMS) has announced (warning: PDF) that once again, it would delay the date on which it will begin enforcement of compliance with the 5010 standard, an ICD-10 prerequisite.  The initial compliance date was January 1, 2012.  CMS announced back in November that it would delay enforcement until March 31, 2012.

Now, CMS will not enforce compliance with 5010 until June 30, 2012.  Recognizing numerous outstanding issues with compliance, CMS decided on another delay.

These delays affect the switch to ICD-10 because 5010 is a prerequisite standard to ICD-10.

Last month, the Department of Health and Human Services or HHS (of which CMS is a part) decided already to initiate a process to delay the switch to ICD-10.  The continued delays in 5010 give some indication of how long the switch to ICD-10 will be delayed, but we hope HHS sees the light and cancels the switch to ICD-10 altogether.

HHS TO START RULEMAKING PROCESS TO DELAY THE SWITCH

The Secretary of Health and Human Services, Kathleen Sebelius, announced today that her Department will initiate the rulemaking process necessary to delay the switch to ICD-10-CM.  This stunning development comes as problems with a required predecessor of ICD-10-CM mount.  This predecessor is the 5010 standard, which we described in a previous post.  Problems with 5010 have been mounting since last summer and fall. Additional pressure has been mounting against 5010 in recent weeks.  Finally, overburdened with unfunded mandates by the federal government, physicians finally began to push back last month, with the AMA urging against the switch (see here and here).

Of course, hospitals and doctors predicted a long time ago that ICD-10-CM and electronic health record adoption would compete for limited resources, and thus that one or the other would have to give. It's long past time that the federal government has seen the light.

We hope that the federal government will similarly come to the realization that the switch is not worth it, and call it off altogether.

Updates on Opposing the Switch to ICD-10-CM

The American Medical Association sent a letter (warning: PDF) on February 2nd to Secretary of Health and Human Services, Kathleen Sebelius, requesting a halt to the switch.  An excerpt from the letter:

In the wake of [an] onslaught of overlapping regulatory mandates and reporting requirements, HHS
has an opportunity to ease the burdens on physician practices by halting the implementation of
ICD-10 and calling on appropriate stakeholders, including physicians, hospitals, payers to assess an
appropriate replacement for ICD-9 within a reasonable timeframe.

In the meantime, the American Health Information Management Association, which lobbied heavily for the switch, urged healthcare providers (including physicians) to keep working (warning: PDF) towards the switch.  They do not expect Congress or the Executive Branch to act to halt the switch.  For sure, we expect them to lobby against any such efforts.

Finally, noted healthcare CIO John Halamka is on record as saying that the switch will have no net financial benefit to the United States heatlhcare sector, public or private (or combined).  He has even lobbied his personal contacts within the federal government to reconsider the switch to ICD-10-CM.  We applaud this stance and his efforts! 

AMA CEO asks House Speaker to halt ICD-10

The CEO of the American Medical Association has asked House Speaker John Boehner to halt the switch to ICD-10-CM in a letter dated January 17, 2012.

Excerpts from the letter:

The implementation of ICD-10 will create significant burdens on the practice of medicine with no direct benefit to individual patient care, and will compete with other costly transitions associated with quality and health IT reporting programs.

The timing of the ICD-10 transition that is scheduled for October 1, 2013, could not be worse as
many physicians are currently spending significant time and resources implementing electronic health
records (EHRs) into their practices.

Physicians must significantly invest in health IT while Medicare payment rates are falling farther below the practice cost inflation each year because of the Medicare sustainable growth rate formula (SGR).

Stopping the implementation of ICD-10, and calling on appropriate stakeholders including physicians, hospitals, payers, national and state medical and informatics associations, to assess an appropriate replacement for ICD-9 will help to keep adoption of EHRs and physician participation in quality and health IT programs on track and reduce costly burdens on physician practices.

Our only question is, what took you so long, AMA?

We've been saying these things for a long time.