Study shows switch will create chaos in measuring patient safety

According to a study published in the January 2015 issue of the Journal of the American Medical Informatics Association, the switch to ICD-10-CM will result in ...substantial hospital safety reporting errors... In other words, the metrics hospitals use to report their performance on patient safety will be so distorted by the switch, valid pre- and post-switch comparisons will result in either (1) underreporting safety, leading patients to unnecessarily doubt the safety of a given hospital or (2) overreporting safety, leading patients to place false confidence in their hospitals.

The reason is that the national system for reporting safety, the so-called Patient Safety Indicators (PSIs) created by the Agency for Healthcare Research and Quality, rely on diagnosis codes for their calculation.  The switch to ICD-10-CM changes the meaning of the calculations, resulting in different PSI values based solely on whether ICD-9-CM or ICD-10-CM is used to compute them.

The study found that of 23 PSIs calculated using ICD-9-CM, 5 PSIs had no mapping to ICD-10-CM, 15 PSIs had 'convoluted' mappings to ICD-10-CM, and only 3 had straightforward mappings to ICD-10-CM.  A 'convoluted' mapping means that the ICD-9-CM code has no equivalent in ICD-10-CM, nor is it a more specific or more general code than the ICD-10-CM code(s) to which it maps.  That is, there is no ICD-10-CM that stands in a parent child relationship with it, or vice versa.

The authors estimated the impact of under- and over-reporting of the 15 convoluted PSIs.  They found a range of 100% underreporting of patient safety to 18% overreporting.

The switch to ICD-10-CM will create chaos for patients trying understand how safe an environment a given hospital offers.  We should not switch.

Disingenuous study underestimates costs of switch to physicians

A recent study published in the Journal of the Healthcare Information Management Association (JAHIMA) estimates the cost of the switch to ICD-10 at $8,167 per physician practice.  Per the study's authors: The ICD-10 expenditures reported in this survey and the two other recent studies are dramatically lower than the $22,560- $105,506 estimate for a small practice in an earlier study commissioned by the American Medical Association (AMA).

However, the JAHIMA study is not comparable to the Nachimson Advisor's study (warning: PDF) they cite, commissioned by the AMA.  The Nachimson Advisor's study did estimate a range of costs from $22,560 to $105,506 per practice.

However, the JAHIMA study did account for all the categories of costs that the Nachimson study did.  Both studies accounted for costs prior to the switch: manuals, ICD-10 documentation, software upgrades, training of physicians and office staff, and so on.

The JAHIMA study did not account for costs predicted to occur after the switch.  These costs include increased documentation costs and cash flow disruption.  Nachimson estimates these costs at $63,500 for a small practice, which far outweigh and dominate the pre-switch costs listed above.

Because the JAHIMA study ignored these costs, it is not comparable to Nachimson nor the true cost of the switch.

The cost of the switch will indeed outweigh its benefits.  Let's stop the switch!

House committee hearing on ICD-10 stacked with proponents of the switch

The United States House of Representatives Energy and Commerce Committee's Subcommittee on Health held a hearing on February 11, 2015 about the switch to ICD-10-CM.  However, the lawmakers on the Subcommittee stacked the deck in favor of the switch: six out of seven individuals spoke in favor of it.

Because the procedure for such testimony involves witnesses submitting a written version of what they will say in person ahead of time, these lawmakers knew the panel was egregiously unbalanced.  Therefore, this Subcommittee had already made up its mind, and the hearing was merely for show, to bolster a predetermined course of action.

Of course, that's how politics works in Washington D.C., so it comes as no surprise.  However, this approach to legislation is exactly why the public has no faith in Congress, and why Congress has the lowest approval rating of any part of the U.S. government.

The token dissenter made similar arguments to what we have put forth here: there is absolutely no need for over 200 codes for diabetes mellitus.  Actually, it's closer to 300.

At least three of the other panelists stand to benefit financially from the switch.  Rich Averill is from 3M Health Information Systems, which creates software to help organizations code with ICD.  A forced upgrade of all their customers to software that accommodates ICD-10-CM will certainly help 3M's bottom line.

Sue Bowman is from the American Health Information Management Association (AHIMA).  This organization represents individuals who code medical records with ICD for billing purposes.  AHIMA creates and sells training materials and courses to its members, so it certainly will see better financials as all its members sign up.

Lastly, Kristi Matus is the chief financial and administrative officer for athenahealth, a healthcare information technology company that sells software and services to physician practices.  Again, the forced upgrades to versions of their software that support ICD-10-CM will boost revenue significantly.

Well, so much for an objective review of the wisdom of the switch, and the possibility of taking wiser and more fiscally responsible courses of action.

Cost of delay nearly three times the cost of the switch?

The Centers for Medicare and Medicaid Services estimates (warning: PDF) that delaying the switch to ICD-10 will cost as much $6.85 billion.  However, its original maximum estimate (see page 3361, warning: PDF) for the entire switch itself was $2.3 billion.

So we're supposed to believe that a one-year delay will quadruple the cost of the switch?  When CMS wants to switch to ICD-10, it's a mere $2.3 billion, but when CMS gets mad about a Congressionally mandated delay, suddenly the delay all by itself costs $6.85 billion?

CMS estimates low when it wants to do something, and high when it does not want to do something. How petty.

President signs bill delaying switch, now it's the law

President Obama signed H.R. 4302 into law on April 1.  Thus the switch to ICD-10 is officially delayed to October 1, 2015.

Bill delaying switch passes Senate, now goes to President

Today the Senate passed without change a bill that delays the switch to ICD-10 by one year, to October 1, 2015.  It's looking better and better for at least one year of relief from the switch.

Senate to vote on bill that delays the switch

After the House of Representatives approved H.R. 4302 which delays the switch to ICD-10 for one year, to Oct 1, 2015, the Senate is set to vote on the bill on Monday 3/31 at 5:30 pm.

The specific language says: The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD-10 code sets as the standard for code sets...

A delay would be good.  Canceling the switch altogether would be better.