The Breathtaking Scope of ICD-10-CM Revisions for 2011

The Centers for Medicare and Medicaid Services just released a 2011 version of ICD-10-CM. A quick look at the "ICD-10-CM 2010 to 2011 Addenda" reveals a breathtaking scope of change.

First, the "Addenda" document (misnamed, since it also includes things removed and edited, not just added) for the tabular index totals 185 pages in a file nearly 1MB in size. Second, the changes span every chapter of ICD-10-CM.

Worse still, is that numerous codes have undergone a change in meaning, something decried by experts in medical informatics over 16 years ago.

Here is an example:

C64.1 Malignant neoplasm of right kidney, except renal pelvis

is now:

C64.1 Malignant neoplasm of left kidney, except renal pelvis

The update also deletes codes, which also militates against best practices in medical terminology management. Deleted codes include C64.0, C65.0, C66.0.

Anyone trying to update software applications that take advantage of particular codes for logic-based processing will surely have to review all 185 pages very carefully to esnure that their logic remains consistent. DRGs will have to be reviewed as well.

These substantial changes just 1.5 years prior to the deadline to switch will increase the cost and complexity of the switch. Another unwelcome development in the long, sad saga of ICD-10-CM.

The cost of the switch, briefly revisited

Prior efforts to estimate of the cost of switching from ICD-9-CM to ICD-10-CM compared the cost to that of Y2K remediation. In a post last year, we also highlighted the comparison.

The American Hospital Association estimates that the cost of Y2K was $8 billion for hospitals. Compare that to the Health and Human Services (HHS) estimate for switching to ICD-10-CM of $1.6 billion.

Now comes the experience of someone who lived through Y2K and now is preparing his hospital for the government-mandated switch.

Stanley Padfield, system director for health information management at four-hospital Lee Memorial Health System, Cape Coral, Fla, considers the cost of the switch to be higher than that of Y2K remediation.

An article describing Padfield's experience notes:

Padfield says tackling the ICD-10 challenge will prove more difficult than Y2K “because there are a lot more variables involved.” Plus, providers that fail to adequately prepare risk not getting paid promptly by Medicare and other payers.

So, the early experience is already that the ICD-10-CM switch will cost hospitals more than the $8 billion they spent on Y2K. Which dwarfs the HHS low-ball figure of $1.6 billion for the entire health care system to switch.

Even the optimistic RAND report that analyzed the cost of the switch could not come up with more than $7.7 billion in benefits to the switch.

So the early signs are that the costs of the ICD-10-CM switch to the health care system will far exceed the benefits.