The Center for Medicare and Medicaid Services (CMS) is sponsoring a conference call to discuss "ICD-10-CM/PCS Implementation and General Equivalence Mappings (Crosswalks)".
The purpose of the call is to discuss "...the General Equivalence Mappings that have been created to assist in converting policies, edits, and trend data from ICD-9-CM to ICD-10-CM/PCS."
In other words, to help the switch to ICD-10-CM from ICD-9-CM go more smoothly, CMS is betting on "General Equivalence Mappings" to help people convert their ICD-9-CM encoded data to ICD-10-CM encoded data. A transition plan might therefore involve continuing to code with ICD-9-CM and then converting those codes to ICD-10-CM. (!)
Sounds easy, right?
That is doubtful.
First, we want to point out the irony of this policy. We were told over and over that we'd get better data from ICD-10-CM coding and the sooner the better. Now, we're being told we can continue coding along merrily in ICD-9-CM and just convert our data to ICD-10-CM afterwards. How could that possibly result in better data?
Furthermore, to use the General Equivalence Mappings (or GEMs), you need to know the following facts, taken from the materials CMS posted for the conference call:
- ICD-9 and ICD-10 codes are quite different
- One ICD-9 Diagnosis Code may be represented by multiple ICD-10 codes
- One ICD-10 Diagnosis Code may be represented by multiple ICD-9 codes
- A few ICD-10 codes have no predecessor ICD-9 codes
- Some payers found GEM detail daunting, therefore they developed a "reimbursement mapping" which is much simpler. It is not clear when to use this mapping vs. GEMs.
- There may be multiple translation alternatives for a source system code (the code being looked up), all of which are equally plausible. This is true of both the ICD-10 to ICD-9-CM GEMs and the ICD-9-CM to ICD-10 GEMs.
- A one-to-one mapping does not imply that the two codes refer to the same disease!
- There are instances where there is not a mapping between an ICD-9-CM code and an ICD-10 code. In these instances, CMS has flagged the code with a "no map" flag.
- Each GEM has FIVE flags:
1. The "approximate" flag
2. The "no map" flag
3. A flag to indicate a one-to-many mapping
4. and 5. Two flags to "further clarify one-to-many mappings".
- CMS et al. developed GEMs "...independently without reference to Medicare data."
- The ultimate goal of the GEMs, and the primary basis on which they are maintained and evaluated, is whether a given patient record receives the SAME Medicare Severity Diagnosis Related Group. Essentially, this means that the improved diagnostic precision of ICD-10-CM is irrelevant to how Medicare will reimburse hospital stays.
- The net effect of the switch and the GEMs on "trend data" (for example, the incidence of hypertension or type 2 diabetes mellitus over time) is not known, and CMS will monitor the effect after the switch.
Why are we switching again?
Showing posts with label CMS. Show all posts
Showing posts with label CMS. Show all posts
Wednesday, May 6, 2009
Saturday, November 15, 2008
Family physicians oppose switch to ICD-10-CM
Much of the opposition to HHS' proposed rule to adopt ICD-10-CM is about the timeline. They have drunk the ICD-10-CM kool-aid, as it were, and simply ask for more time to make the switch from ICD-9-CM.
However, we recently uncovered opposition to switching at all. On behalf of the American Academy of Family Physicians (AAFP), Dr. Jim King writes a letter in response to the proposed rule.
Here are some highlights of the letter:
The AAFP does not support the transition to ICD-10-CM because we do not find that there is good rationale for making such a significant change.
The purported benefits of the transition to 68,000 ICD-10-CM diagnosis codes are largely based on assumptions and not supported with any real world trial involving practicing physicians in the United States.
Our recommendation that CMS not adopt ICD-10-CM is further supported with the following:
The AAFP has been at the vanguard of electronic health record (EHR) adoption. They have been a key driving force behind the creation of health care information technology standards, including the continuity of care record and continuity of care document.
This opposition does not therefore come from a small, fringe group. Nor does it come from a group that is backwards in its thinking with respect to health care information technology.
The Centers for Medicare and Medicaid Services would do well to listen to those doctors who are at the forefront of using information technology to improve healthcare. They should drop their plan to switch to ICD-10-CM.
As a postscript, we note that in our third post, we criticized the AAFP for not opposing the switch. We hereby withdraw that criticism!
However, we recently uncovered opposition to switching at all. On behalf of the American Academy of Family Physicians (AAFP), Dr. Jim King writes a letter in response to the proposed rule.
Here are some highlights of the letter:
The AAFP does not support the transition to ICD-10-CM because we do not find that there is good rationale for making such a significant change.
The purported benefits of the transition to 68,000 ICD-10-CM diagnosis codes are largely based on assumptions and not supported with any real world trial involving practicing physicians in the United States.
Our recommendation that CMS not adopt ICD-10-CM is further supported with the following:
- Enhancement and adoption of electronic health records (EHR) must come first
- ICD-9-CM diagnosis codes meet the needs of patient care
- Biosurveillance and research needs can be met through the mapping of ICD-9-CM to ICD-10-CM
- Disease management programs are not dependent on diagnosis codes
- CMS’s estimates of coding education needs are not accurate
- Changes required for adoption of ICD-10 are substantial
- Lack of resources to support physician adoption
The AAFP has been at the vanguard of electronic health record (EHR) adoption. They have been a key driving force behind the creation of health care information technology standards, including the continuity of care record and continuity of care document.
This opposition does not therefore come from a small, fringe group. Nor does it come from a group that is backwards in its thinking with respect to health care information technology.
The Centers for Medicare and Medicaid Services would do well to listen to those doctors who are at the forefront of using information technology to improve healthcare. They should drop their plan to switch to ICD-10-CM.
As a postscript, we note that in our third post, we criticized the AAFP for not opposing the switch. We hereby withdraw that criticism!
Tuesday, August 19, 2008
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.
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.
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