Authored by the Coalition for ICD-10 on January 13, 2015

In what at times feels like an unending barrage of excuses why the U.S. should further delay moving to ICD-10, one of the frequently repeated reasons is that we should wait until ICD-11 is ready for implementation.

This excuse is reminiscent of Samuel Beckett’s play Waiting for Godot:

“Let’s go.” “We can’t.” “Why not?” “We’re waiting for Godot.”

Based on the World Health Organization’s (WHO) current timeline, ICD-11 is expected to be finalized and released in 2017. For the U.S., however, that date is the beginning, not the end. As with every WHO version of the ICD codes, ICD-11 would need to be adapted to meet the detailed payment policy, quality assessment and other regulatory requirements of U.S. stakeholders.

The modification of the WHO version of ICD-10 for use in the U.S. took eight years. It was another eleven years before the regulatory process of proposed rules and comment periods was completed and the issuance of a final rule establishing ICD-10 as the HIPAA standard code set. The ICD-10 final rule gave the industry three years to get ready for ICD-10 implementation. Two one-year delays have now pushed the time allotted for preparation to five years. Based on the ICD-10 timeline, ICD-11 would not be implemented until 2041.

It’s now 16 years since the U.S. version of ICD-10 was completed, five years since publication of the ICD-10 final rule, and the U.S. still has not implemented ICD-10. For the many healthcare organizations that worked diligently and in good faith to prepare for ICD-10, the lament in Waiting for Godot is all too true:

“Nothing happens. Nobody comes, nobody goes. It’s awful.”

The U.S. simply cannot wait decades to replace ICD-9, a code set that was developed nearly 40 years ago. U.S. healthcare data is deteriorating while at the same time demand is increasing for high-quality data to support healthcare initiatives such as the Meaningful Use EHR Incentive Program, value-based purchasing, and other initiatives aimed at improving quality and patient safety and decreasing costs.

Moreover, implementing ICD-10 is an important step on the pathway to ICD-11. ICD-11 is built on ICD-10 and benefits from the clinical knowledge and additional detail that have been incorporated into the U.S. version of ICD-10. Transitioning to ICD-10 in 2015 will provide an easier and smoother transition to ICD-11 at some point in the future.

Indeed, a 2013 report^[1] on the feasibility of skipping ICD-10 and going right to ICD-11, published by the American Medical Association Board of Trustees, recommended against waiting for ICD-11 and called it fraught with pitfalls. The AMA report concluded that overall implementation and training efforts for ICD-11 will be more challenging if ICD-10 is not implemented first, and the U.S. would miss out on improvements in the ICD-10 codes that better align with today’s data needs.

Waiting for ICD-11 is simply not a viable option. The absurdity of the endless waiting in Waiting for Godot culminates in frustration:

“Let us not waste our time in idle discourse! Let us do something, while we have the chance!”

Yes, the wait needs to be over. It’s time to stop wasting time. It’s time to get ICD-10 implemented.

[1] American Medical Association. “Evaluation of ICD-11 as a New Diagnostic Coding System.” Report of the Board of Trustees. 2013. http://www.ama-assn.org/assets/meeting/2013a/a13-bot-25.pdf.

The Workgroup for Electronic Data Interchange (WEDI) has released the results of its latest ICD-10 readiness survey released in February 2015. The findings suggest that while there has been incremental progress along some activities, the uncertainty created by past delays is a catalyst for stagnation that could put entities at risk come October 1, 2015. Based on responses from 1174 participants including 796 providers, 173 vendors, and 203 health plans, an increase of more than 100% from the August 2014 survey, WEDI summarized its findings in its March 31, 2015 letter to Department of Health & Human Services Secretary Sylvia Mathews Burwell.

• Compliance date uncertainty: Uncertainty around further delays was listed as a primary obstacle to implementation, appearing on more than 50 percent of all responses for vendors, health plans and providers.
• Health plan testing: More than 50 percent of health plans have begun external testing, and of these, a few have completed testing. This is a slight improvement from the prior survey.
• Vendor product availability: About 60 percent indicated their vendor products were available or they had started customer testing. This is a slight decrease from about two-thirds in the August 2014 survey. However, the number that responded ‘unknown’ decreased from one eighth to just a handful.
• Provider testing: Only 25 percent of provider respondents had begun external testing and only a few others had completed this step. This is actually a decrease from the about 35 percent of provider respondents that had begun external testing in the August 2014 survey.

Independent of the state of industry readiness, NYP continues to be ahead of the curve in both its diligence, remediation, and testing activities as it moves toward an internal ICD-10 implementation date of July 1, 2015.

To view WEDI press release and the letter to Secretary Burwell, click here.

 

 

 

Sports teams often look for that seminal moment. That game, that play, that trade where the fortunes of a season, an organization are transformed. For ICD-10 let’s call that day February 11, 2015. The day that the House and Energy Commerce Committee’s sub-committee on Health heard from industry constituents about the state of ICD-10 readiness and its ability to facilitate transformation in healthcare.

Individuals representing physician groups, hospitals, HIM trade associations, insurance carriers, and technology vendors led what was largely a congressional cheerleading session (with some diplomatic governmental bashing for good measure) supporting the current implementation date of October 1, 2015. Benefits were touted, support of other government initiatives including meaningful use and value based reimbursement were articulated, myths were dispelled, and stories of success were shared.

If this never ending season of ICD-10 is to turnaround, perhaps this was that seminal moment we are all looking for. A selection of quotes from speakers is included below. For a full transcript of presentations and video testimony click here.

• Edwin M. Burke, MD, Beyer Medical Group: “On a busy Monday morning, October 7, 2013 we took on ICD‐10 and we haven’t looked back. We did not have special training. We did not spend ANY money in preparation. We did not see less patients and our practice did not suffer. As providers, it was not frustrating or scary. It just ‘was’”.
• Rich Averill, Director of Public Policy, 3M Health Information Systems: “The biggest frustration with DRGs updates is that reasonable proposed DRG modifications from the health care providers often cannot be considered because there are no ICD-9 codes available to evaluate the proposal”.
• Sue Bowman, Senior Director, Coding Policy and Compliance, American Health Information Management Association: “The development of ICD-10 involved extensive input from the healthcare industry, particularly the physician community. A number of physician organizations, including medical specialty societies, continue to actively participate in the ongoing maintenance of ICD-10 by requesting additional clinical detail. Ninety-five percent (95%) of the requests for new ICD-10-CM codes in the past three years came from physician organizations”.
• Kristi A. Matus, Chief Financial and Administrative Officer, Athena Health: “Repeated delays in deadlines associated with key goals of our nation’s ambitious, bipartisan healthcare agenda undermine the government’s credibility and impede progress on crucial initiatives”.
• William Jefferson Terry, MD, Mobile Urology Group: “CMS and the coding industry have said that it can take a year to adequately prepare for this transition. If we must transition, ICD-10 implementation should be incremental – carried out over 2-3 years, which we believe CMS and other health insurers’ administrative systems are capable of”.
• Carmella Bocchino, Executive Vice President of Clinical Affairs and Strategic Planning, America’s Health Insurance Plans: “…the more specific diagnosis and procedure information in ICD-10 will support better correlation of the outcomes achieved from different medical processes, yielding much more actionable clinical outcome information and an improvement in care quality.”
• Dr. John Hughes, Professor of Medicine, Yale University: “…techniques such as minimally invasive surgery, which have been increasingly and successfully used in cardiac surgery, and are rapidly expanding into other surgical fields, cannot not be adequately described using the simplistic four digit structure of ICD‐9”.

Despite months of positive progress.  Despite endorsements from the General Accounting Office (GAO).  Despite an overwhelming amount of support in favor of implementing ICD-10 at a recent hearing in front of the House Energy and Commerce Committee’s subcommittee on Health, and despite his own words suggesting if not outright indicating the October 1, 2015 implementation date would be met, the American Health Information Management Association (AHIMA) has received word that Chairman Pete Sessions (R-Tx) is now looking to draft legislation to once again delay ICD-10.  As such, AHIMA is asking its constituents and the industry as a whole to call your local congressman to advocate for no further ICD-10 delay.  The organization’s instructions are listed below.

As a reminder, NYP is in full support of the transition to ICD-10 and is operationally, clinically, and financially ready to implement these new code sets.  The increased specificity of ICD-10 enables NYP to truly communicate the amazing care it provides to its patients every day.

Call these legislators today and voice your support for ICD-10 in 2015.  Note, this will be the most critical month in Congress to ensure the new code sets are implemented this year.  You can follow these 4 easy steps:

1) Call Dr. Michael Burgess at (202) 225-7772

2) State that you support ICD-10 implementation in 2015.

3) Use the talking points below:

• We need the code sets in 2015!
• A recent GAO report supports ICD-10 readiness
• Small physician practices are expected to spend between $1,900 and $6,000 to transition to the new code set.  This is much lower than previous reports.  The study can be found on coalitionforICD-10.org

4) You can additionally call these congressmen to voice your support:

• Chairman Pete Sessions                            TX-32                                      (202) 225-2231
• Rep. Virginia Foxx                                       NC 5                                        (202) 225-2071
• Rep. Tom Cole                                             OK 4                                        (202) 225-6165
• Rep. Rob Woodall                                       GA-7                                       (202) 225-4272
• Rep. Steve Stivers                                       OH-15                                     (202) 225-2015
• Rep. Doug Collins                                       GA-9                                        (202) 225-9893
• Rep. Louise Slaughter                                NY-25                                      (202) 225-3615

 

Efforts by the Centers for Medicare and Medicaid Services to prepare providers, clearinghouses, and health plans for the October 1 ICD-10 deadline are on track, and CMS is ready to process claims using the new codes.

That is the conclusion of a just-released Government Accountability Office report on the readiness of CMS for the ICD-10 switchover.

“The transition to ICD-10 codes requires both CMS and covered entities to develop, test, and implement information technology systems that can process the new codes,” states the GAO report. “In addition, these covered entities need to educate and train staff in using these new codes, and may need to modify internal business processes.”

According to GAO, CMS has developed various educational materials, conducted outreach, and monitored the readiness of covered entities and the vendors that support them for the ICD-10 transition. For example, the agency held in-person training for small physician practices in some states and monitored readiness through stakeholder collaboration meetings, focus group testing, and reviews of industry surveys, finds the report.

GAO also reported that CMS modified its Medicare systems and policies. For example, the agency completed all ICD-10-related changes to its Medicare fee-for-service (FFS) claims processing systems. Auditors also found that the agency provided technical assistance to Medicaid agencies and monitored their ICD-10 readiness. As a result, all Medicaid agencies reported that they would be able to perform all of the activities that CMS has identified as critical by the October 1 implementation deadline.

Nonetheless, while CMS’s Medicare FFS claims processing systems have been updated to reflect ICD-10 codes, GAO states that “it is not yet known whether any changes might be necessary based upon the agency’s ongoing external testing activities.” Auditors also conclude that although CMS has worked with states to help ensure that their Medicaid systems are ready for the ICD-10 transition, “in many states, work remains to complete testing by the transition deadline.”

At the same time, GAO reports that stakeholder organizations identified several areas of concern about the ICD-10 transition and made several recommendations, which CMS has taken steps to address. For example, stakeholders expressed concerns that CMS’s testing activities have not been comprehensive. To address this concern, CMS officials said that the agency has scheduled end-to-end testing with 2,550 covered entities during three weeks in 2015 (in January, April, and July).

In response to the GAO report, Senate Finance Committee Chairman Orrin Hatch (R-Utah) and Ranking Member Ron Wyden (D-Ore.) issued a statement saying they have “confidence” that CMS is “adequately preparing to implement” ICD-10 by the October 1 deadline. “As demonstrated by this report, the provider outreach and responsiveness to stakeholder concerns from CMS have kept the agency on track to upgrade to the next level of healthcare coding,” said Hatch. Wyden added that CMS has “taken unprecedented actions to help providers prepare for this change.”

Similarly, the Coalition for ICD-10 in a statement said that the GAO report “affirms widespread recognition across the healthcare industry that CMS is well-prepared to implement the U.S. transition to ICD-10 on October 1, 2015, and that the agency has undertaken extensive efforts to help the health care industry prepare,” adding that “the U.S. is ready to move forward with ICD-10