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By James Swann
Industry groups remained divided in their reaction to a proposed one-year delay in the implementation of the ICD-10 code set, with some calling for a longer implementation delay and others rejecting any need for a delay, according to comment letters submitted to the Centers for Medicare & Medicaid Services in advance of a May 17 deadline.
The American Medical Association's letter, for example, urged CMS to extend the deadline to at least Oct. 1, 2015, and suggested that an indefinite delay might be preferable.
“A year's delay does not provide CMS with adequate time to fully examine the appropriate scope of ICD-10 and true costs to physician practices. If stakeholders cannot reach consensus on this matter during this two-year delay period, then the move to ICD-10 should be postponed indefinitely,” James L. Madara, AMA executive vice president and chief executive officer, said in his letter dated May 10.
The comment letters were in response to a proposed rule from CMS published in the April 17 Federal Register that would move the compliance date for the International Classification of Diseases, 10th Revision (ICD-10) code set from Oct. 1, 2013, to Oct. 1, 2014 (68 HCDR, 4/10/12).
ICD-10 is intended to be used for classifying health care diagnoses and procedures, and entails moving from the 13,000 codes of ICD-9 to roughly 68,000 codes. The expanded code set will allow for the inclusion of new conditions and treatments, and will allow for more granular data.
The AMA letter said a longer ICD-10 delay would enable CMS to conduct a cost-benefit analysis of the administrative and financial burdens associated with transitioning to the full ICD-10 code set.
Providers are already facing administrative burdens associated with implementing multiple health information technology programs, such as the electronic health record “meaningful use” incentive program and the physician quality reporting system (PQRS), AMA said, and a physician practice can spend anywhere from $83,290 to over $2.7 million moving to ICD-10, depending on the practice size.
In addition to calling for a longer delay in implementation, AMA said CMS should work to align its health IT programs to make participation easier and to avoid unnecessary penalties.
“Physicians are also overwhelmed with the simultaneous implementation of multiple health IT programs and are being forced to prioritize which initiatives they are able to meet based on the potential incentives and penalties and their impacts on their reimbursement,” the AMA said.
“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,” the letter said, noting that while many countries have implemented ICD-10, they have not implemented the entire code set.
Taking the opposite tack, the American Health Information Management Association (AHIMA) argued for no delay in ICD-10 implementation in its April 24 comment letter.
AHIMA represents over 64,000 health information management professionals, both in the United States and abroad.
“Setting back the compliance date ignores both the efforts of the healthcare industry and the ability to use the much-improved data code sets to support the crucial data needed to move the nation toward an electronic health record (EHR) and exchange infrastructure that will improve the quality of care through more detailed data, as well as improve our public health, quality, and outcomes data, provide information for better research, and lower the cost of delivering care,” Dan Rode, AHIMA's vice president for advocacy and policy, said in the letter.
AHIMA also said it was concerned that moving the ICD-10 deadline to 2014 would impact the implementation of Stage 2 and Stage 3 of the meaningful use incentive program. AHIMA asked that CMS clarify how a delay in implementing ICD-10 would affect future phases of the meaningful use program because proposed rules for Stage 2 of the incentive program specify the use of ICD-10 codes.
Additional CMS programs, including accountable care organizations (ACOs) and value-based purchasing, could also be adversely affected by any ICD-10 delay, AHIMA said.
If the original October 2013 implementation date cannot be maintained, AHIMA said, any delay should be limited to no longer than one year so as to avoid any ill effects to health care from the continued use of the existing ICD-9 code set.
“Until the ICD-10-CM/PCS code sets are implemented, U.S. health data will continue to deteriorate, at a time when there is an increasing number of data-dependent healthcare initiatives aimed at improving value,” AHIMA said.
Assuming the one-year delay holds, CMS should consider offering grants or scholarships to health care information management students who will have to learn ICD-10 as well as ICD-9.
The delay “will require students--already at a difficult point in their careers, and potentially [with] no job--to both maintain the skills associated with ICD-10-CM/PCS and take additional coursework to learn ICD-9-CM for a limited period of time,” AHIMA said.
AHIMA also said CMS should consider working with coders to help them maintain their proficiency in ICD-10 over the course of the one-year delay.
The College of Healthcare Information Management Executives (CHIME) said it supported the proposed rule's one-year implementation delay, according to its comment letter released May 9.
CHIME represents chief information officers and other senior health care IT executives.
The letter said the one-year delay was a good balance between groups who favored a longer delay and those who advocated for no change at all.
“A longer delay would seriously disrupt ongoing efforts to convert to ICD-10,” Richard A. Correll, CHIME president and CEO, and Drex Deford Sr., CHIME chairman and vice president and chief information officer at Seattle Children's Hospital, said in the letter.
CHIME also said CMS should reject any suggestions to skip the ICD-10 transition and move directly to ICD-11.
“While the maturity of ICD-11 may hold great benefits in the future, we believe such claims are speculative, at best, because so much is yet to be developed,” CHIME said.
By James Swann
The AMA comment letter is at http://www.ama-assn.org/resources/doc/washington/icd-10-comment-letter-10may2012.pdf. The CMS proposed rule is at http://www.gpo.gov/fdsys/pkg/FR-2012-04-17/pdf/2012-8718.pdf. The AHIMA comment letter is at http://ahima.org/downloads/pdfs/advocacy/Comment%20LTR%20on%204-17%20ICD-10%20NPRM_fin%2020120508.pdf. The CHIME comment letter is at http://www.cio-chime.org/advocacy/resources/download/CHIME_Comments-Change_to_the_Compliance_Date_for_ICD-10.pdf.
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