On December 5, 2014, the American Hospital Association (AHA) issued a letter to Congressional leaders on behalf of its members imploring them to continue supporting the ICD-10 implementation date of October 1, 2015. Citing additional costs and disruptions of further delays along with the improved collaboration between the payer, provider, and government communities, the AHA is confident that the industry will be ready for the transitions which is now less than one year away.
Industry & Regulatory Updates
No ICD-10 Delay included in recently passed Omnibus spending bill
Written by Chuck Buck, ICD-10 Monitor
Despite a significant lobbying effort mounted by a small but very vocal minority within the healthcare industry, the implementation of ICD-10 is expected to proceed without further delay.
The failed push marked a third attempt to delay the Oct. 1, 2015 ICD-10 implementation deadline well into 2017. Members of Congress rejected the request to include language that would again delay ICD-10 in the lame-duck omnibus spending bill that was passed by Congress on Dec. 11 and ratify by the Senate on Dec. 13.
Failing to delay ICD-10 by using a legislative maneuver – slipping language in a massive spending bill – represents a crippling blow to opposition that will make future efforts to revisit the matter very difficult. Congress made its decision not to hold up ICD-10 after hearing opinions about it from many voices in the healthcare community, including well-organized groups of physicians. During the course of this debate, there were many myths perpetuated, not to mention promises of doom and dysfunction, but also strong cases for proceeding with the coding system upgrade.
While fans of ICD-9 will no doubt use the March 2015 sustainable growth rate (SGR) bill to make another run at delaying implementation, it will be hard to convince members of Congress that more time is needed. If Congress didn’t see the need to enact a delay in December, why would they be convinced to delay months later in March?
Advocates for ICD-10, including the American Health Information Management Association (AHIMA), national and regional hospital associations, and physician groups are applauding the decision by Congress. Across the industry, companies and healthcare organizations have invested millions of dollars preparing for ICD-10. Many physicians have planned ahead for ICD-10 by taking advantage of low- and zero-cost education resources made available by the government.
Upon hearing the news that ICD-10 cleared a major legislative hurdle, organizations issued statements expressing their support for moving forward on this long-awaited and much-needed move to implement.
“Congress issued a strong message and sent the ‘delay ICD-10’ crowd back to the bench,” said Chris Powell, CEO of Precyse, a provider of health information management solutions and staunch advocate for ICD-10.
“I predict that, in a short time, the industry will look at the upsides of a modern coding system and wish that ICD-10 had arrived much sooner,” added Powell. “The vast majority of the industry is ready to move beyond ICD-9, an antiquated and very limited system that is woefully insufficient for hospitals, physicians, and patients. We have a myriad of best practices and learnings gained from other countries’ migrations to ICD-10 before us, and we now have the green light to put ICD-10 into motion.”
ICD-10 delay appears DOA in Congress this year
by Joseph Conn & Paul Demko
A proposal to delay implementation of ICD-10 diagnostic and procedure codes by an additional two years appears to be going nowhere in the current lame duck session of Congress.
“That’s not going to happen,” said a veteran healthcare consultant who tracks the issue closely, speaking on background. “The reports of them ever getting traction were overrated.”
The Texas Medical Association has been lobbying for the two-year delay. The nation’s largest state medical society for physicians, with 48,000 members, wants to push back the adoption date for the oft-delayed change to 2017.
The association’s position apparently found a champion in Rep. Pete Sessions (R-Texas), a nine-term incumbent who currently chairs the House Rules Committee. Sessions raised the possibility with House leadership of including such a provision in the budget agreement—what’s being billed the “cromnibus”—to keep the government funded, according to sources familiar with the discussions. Sessions’ office didn’t respond to a request for comment about the issue.
The federal government is set to run out of money Dec. 11 if Congress doesn’t authorize additional spending, making a funding bill a perfect vehicle for attaching special causes such as an ICD-10 delay since the overall bill must pass to keep the government open.
But the proposed ICD-10 delay, which would infuriate other interested healthcare parties that have been moving forward with plans to implement the coding changes next year, doesn’t appear to be going anywhere.
“(Sessions) definitely did make a play for it,” said the consultant, who has spoken with staffers in the offices of both the Republican and Democratic leadership. But “we are being told it is not going to happen.”
Coalition for ICD-10 Responds to AMA President Dr. Robert Wah
In his recent speech to the AMA House of Delegates, AMA president Dr. Robert Wah characterized the planned implementation of ICD-10 as analogous to the dark forces controlling the galaxy in the movie Star Wars:
“If it was a droid, ICD-10 would serve Darth Vader… For more than a decade, the AMA kept ICD-10 at bay – and we want to freeze it in carbonite!”
Dr. Wah’s attempt at humor is unfortunate because the quality and precision of our national health care data is a serious matter. In this country, we use coded data to assess quality of care, make benefit coverage decisions and to determine physician and hospital payment. The financial viability and performance assessments of hospitals and physicians are impacted by the data. Yet we continue to rely on an outdated 1970s-era coding system for reporting diagnoses and inpatient hospital procedures.
In his speech, Dr. Wah goes on to lament:
“Sucked into a jet engine? Burned by flaming water skis? Yes, there are codes for that.”
While at first glance these examples appear humorous, it is important to understand that these cause of injury codes were included in ICD-10 to meet the needs of organizations like the Department of Defense (aircraft accidents are an important issue for the military) and Worker’s Compensation (in waterski shows the burning waterski trick can lead to a worker’s comp claim). Should our national coding system ignore the needs of the Department of Defense and Worker’s Compensation?
Using cause of injury codes to imply that the coding detail in ICD-10 will be a burden to physicians is at best disingenuous because physicians are not required to report cause of injury codes, except in very limited situations such as injuries caused by medical treatment, like removing the wrong limb. Furthermore, the current ICD-9 system has similar cause of injury codes and their existence has never been a burden.
Dr. Wah continues to criticize by stating:
“We’d see 13,000 diagnosis codes balloon into 68,000 – a five-fold increase.”
Again, the inference is the increase is unnecessary and will be a burden for physicians. This is like saying the English language is a burden to use because there are 470,000 words in Webster’s unabridged English dictionary. Just as no one is expected to know rarely used words like floccinaucinihilipilification or use all 470,000 words, physicians and other providers will only use the codes relevant to their patient population (e.g., an ophthalmologist will primarily use only the eye codes).
The notion that more codes create a burden is out of touch with today’s digital world. As with almost everything else, there’s an app for that. In fact, there are more than 50 ICD-10 iPhone apps that allow a person to use word search to find an ICD-10 code instantaneously. Ranging from $1.99 to $10.99, the cost isn’t a burden (there are even a few free versions).
Dr. Wah complains about the number of codes and the detail in ICD-10 but fails to mention that much of the additional specificity in ICD-10 was at the request of medical specialty societies. Nor does he mention that there are no ICD-9 codes for many critical healthcare issues. There is no code to report and track Ebola. There are inadequate codes for tracking service-related health problems for our veterans. There are no codes to help us research sports-related concussions among young athletes. It’s hard to understand why the AMA is not demanding that this kind of information be available in our national data.
Dr. Wah goes on to state:
“We all know ICD-10 is expensive to implement. We don’t know if it will improve care.”
While there are significant costs associated with the implementation of ICD-10, the vast majority of the health care industry has already incurred those costs. In our digital world, the infrastructure for a systems change like ICD-10 has to be built and tested well in advance. These are sunk costs which will be lost if ICD-10 is not implemented. Indeed, CMS has estimated that the health care industry has already invested billions in preparation for ICD-10: “Forgoing ICD-10 translates into a loss of up to $22 billion for the U.S. health care industry” (Federal Register, 77(172), p 54689).
As to whether ICD-10 will improve care, it would seem obvious that more precise data should lead to better identification of potential quality problems and assessment of provider performance. There are multiple provisions in current law that alter Medicare payments for providers with excess patient complications. Unfortunately, the ICD-9 codes available to identify complications are woefully inadequate. If a patient experiences a complication from a graft or device, there is no way to specify the type of graft or device nor the kind of problem that occurred. How can we as a nation assess hospital outcomes, pay fairly, ensure accurate performance reports, and embrace value-based care if our coded data doesn’t provide such basic information? Doesn’t the public have a right to know this kind of information?
Our national healthcare data is broken due to the use of an archaic coding system. Given Dr. Wah’s “freeze it in carbonite” comment, it is clear that he is not really interested in a delay of ICD-10 but instead wants ICD-10 to never be implemented. It is hard to fathom why anyone would promote having our national data fail to meet the demands of 21st century health care. This is especially perplexing given that ICD-10 has been adopted by virtually every other country.
In attempting to relegate ICD-10 to the equivalent of “a galaxy far, far away,” Dr. Wah inexplicably ignores the implications for U.S. health care if we continue to use ICD-9 codes. This isn’t about waging a mythic battle (with sound bites instead of light-sabers). It’s about improving quality of care and patient safety in the here and now. It’s about ensuring fair payment, and in the case of Ebola, it’s about protecting our citizens. Yoda from Star Wars said it best: “Always in motion is the future…a little more knowledge lights our way.”
Will ICD-10 be Delayed Again?
by Dan Haley, VP of Government and Regulatory Affairs
See full article here.
Is the October 2015 deadline real this time? Are the feds going to punt again? They aren’t ever going to pull the trigger on ICD-10, right?
All reasonable questions, especially after the October 2014 deadline — supposedly a hard-and-fast date — was unceremoniously kicked down the road by a year.
When it comes to ICD-10, providers fall generally into two categories: Those who actually invested time and money to be ready for October 2014, and, having been burnt once badly, are leery of approaching the ICD-10 stove again. Then there are providers who feel validated that they had correctly bet the feds would blink — and may be more comfortable making that bet again next year.
The policy meteorologists uniformly predicted stormy weather. Yet a whole lot of people went outside without an umbrella and ended up enjoying a beautiful, sunny day. Why shouldn’t the same scenario play out again in 2015?
Despite all of the time I spend in the company of federal health IT policymakers, I have precious little insight to offer. The people in DC who are in charge of the transition are emphatic, both in public and behind closed doors: this time, they say with uniform certitude, the deadline is real. Count on it. Tomorrow the sun will rise in the east, this winter the New England Patriots will make the playoffs (hey, I’m in Boston), and in October 2015, the nation will switch over to ICD-10.
Considering past performance as an indicator of future action, skeptics can certainly be forgiven for their lack of faith. So how can we at athenahealth say, with a straight face, we think this thing might just be real this time? A few reasons:
- The 2014 delay was almost certainly political. With the nation just barely over the calamitous roll-out of healthcare.gov, there was no way the White House would implement a massive code switchover that could well have rendered a majority of the country’s providers temporarily unable to be paid for their services, just one month before the midterm elections. Unequivocal statements by everyone including Centers for Medicare & Medicaid Services (CMS) head Marilyn Tavenner notwithstanding, this year’s delay was entirely predictable. 2015, on the other hand, is not an election year. Even if providers are not appreciably better prepared for ICD-10 next year than they were in 2014, it may not matter — chaos is more politically palatable in an off year.
- The recent Ebola scare lends a new degree of urgency to upgrade U.S. systems to match the code set already in use in much of the world, to better enable the disease identification and tracking necessary for a global health crisis response. Nothing motivates change in Washington like an emergency.
- Of course, there is the Affordable Care Act. With the rolling implementation of the law, provision of and reimbursement for care is getting more complex. At some point, the continued use of a code set rolled out in the Watergate era, and long-retired in much of the modern world, becomes untenable.
Regardless of the continued uncertainty surrounding the October 2015 deadline, at athenahealth we are encouraging providers to get ready for ICD-10 and are preparing and testing on our clients behalf. Our cloud platform had our entire provider base ready well before October 2014, and will have it ready again months before October 2015, at no additional cost to those clients. And we are working hard — again — to make the transition as easy and painless as possible.
Like meteorologists, political prognosticators are often wrong, sometimes radically so. Even though we sometimes get to enjoy unexpected blue skies, eventually it pays to dress for stormy weather. DC is again confidently predicting a switch to ICD-10 on October 1, 2015, and there is no upside to bet against that happening. No matter when it does, athenahealth will be holding the umbrella for providers.
ICD-10 and Value Based Purchasing (VBP)
Written by Gregory M. Adams, FHFMA
See full article here
According to the group Catalyst for Payment Reform, of the value-based payment models in action, 53 percent of commercial payer VBPs put providers at some financial riskif they fail to contain costs or improve care.
However, on the flip side, many value-based payments still fall into the category of pay-for-performance, which offers providers only potential financial rewards and no risk. I believe that the progression of VBPs will move quickly away from this model into models that will penalize providers for poor quality.
This is already being done by the Medicare program, which is seeing to it that hospitals are slapped with big penalties that experts say are only increasing. A recent study from CipherHealth shows a mounting $1.6 billion in Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) and readmission penalties facing hospitals today. That’s $1.6 billion! The survey calculated that at more than 500 hospitals nationwide, the three-year at-risk amounts were $3,500 per inpatient bed.
Based on a study by the PWC Health Research Institute, the financial impact of these value-based reforms is expected to have a significant impact on low-performing hospitals. For example, a 300-bed hospital with poor quality metrics would be penalized approximately $1.3 million a year, beginning in 2015, under Centers for Medicare & Medicaid Services (CMS) value-based reforms. And this doesn’t consider the impact of reduced payments from commercial payers. In this example, if we assume that another 30 percent of the hospital’s revenue is commercial, using the same penalty relationship, the hospital would lose over $2 million a year.
Now, let’s put that number into perspective – while profitability for hospitals increased overall in 2012, there was a wide disparity in hospital performance, with over 30 percent of hospitals running at a loss. For those hospitals, even a small decrease in payments will strain resources. So, how does a hospital fix any quality issues through changes in operational practices, which will cost money, while receiving less in payments? It will not be easy, and keep in mind that any quality comparisons, at least at the federal level, are a moving target. Under the current CMS formula, not only do providers need to improve their scores, they need to improve at a faster rate than other hospitals nationally to benefit.
Now how does VBP relate to ICD-10? Well, the accuracy and completeness of coding drives many of the quality and severity-of-illness indicators that in turn determine value-based payments or penalties. And with the increased complexity of coding under ICD-10, the potential for inaccurate coding increases exponentially. On top of that is the uncertainty of how both CMS and commercial payers will change their measurement criteria for quality and value with the increased specificity of the ICD-10 codes. With all of these unknowns, one thing is clear – clinical documentation is, or should be, a top priority for every provider. The accuracy and preciseness of the coding of a patient’s record ultimately will affect VBP payments and whether reimbursement decreases, increases, or stays the same during the ICD-10 transition. Millions of dollars are hinging on your clinicians and coders, so here are two tactics to help you tackle these transitions.
Workgroup for Electronic Data Interchange (WEDI) releases latest ICD-10 readiness survey results
The Workgroup for Electronic Data Interchange (WEDI), the nation’s leading nonprofit authority on the use of health IT to create efficiencies in healthcare information exchange, announced the release of its findings from its August 2014 ICD-10 Industry Readiness Survey. The latest survey results are based on responses from 514 respondents, consisting of 324 providers, 87 vendors and 103 health plans.
Since 2009, WEDI has conducted nine ICD-10 readiness surveys in an effort to gain a broad perspective on the readiness status for different sections of the industry, and to gauge how quickly they are progressing towards the Oct. 1, 2015 implementation deadline. The full survey results are contained in WEDI’s September 19 letter to the Department of Health and Human Services (HHS) which can be viewed online via the WEDI website. Highlights from the latest survey findings include:
- Vendor product development: About 40 percent of vendors indicated they are complete with product development. This is an improvement over the October 2013 survey.
- Vendor product availability: More than 25 percent of vendors responded that their products would not be ready until 2015 or responded ‘unknown.’
- Health plan impact assessments: Nearly 75 percent of health plans had completed their impact assessment.
- Health plan testing: More than 50 percent of health plans have already begun external testing compared to less than 25 percent in the prior survey.
- Provider impact assessments: About 50 percent of the providers indicated they have completed their impact assessment—essentially the same number as in the October 2013 survey.
- Provider testing: About 35 percent of providers have begun external testing, while in the October 2013 survey about 60 percent had expected to begin by the middle of 2014.
- External testing approach: About 60 percent of health plans expect to test with a sample of providers, while about 20 percent indicated they will test with a majority of providers.
“Based on the survey results, all industry segments appear to have made some progress since October 2013, but the lack of progress by providers, in particular smaller ones, remains a cause for concern as we move toward the compliance deadline,” said Jim Daley, WEDI chairman and ICD-10 Workgroup co-chair. “Delaying compliance efforts reduces the time available for adequate testing, increasing the chances of unanticipated impacts to production. We urge the industry to accelerate implementation efforts in order to avoid disruption on Oct. 1, 2015.”
WEDI will continue its efforts to move the industry forward and plans to continue its surveys to gauge industry readiness. WEDI has conducted several ICD-10 forums—the most recent of which was in July 2014—and plans to hold additional events in 2015, as well as continue to provide educational opportunities and produce work products to assist the industry in preparing for ICD-10 implementation. More information on WEDI events and ICD-10 work products are available on the WEDI website.
New ICD-10 Implementation Date Finalized
On Thursday, July 31, 2014, the Department of Health & Human Services (HHS) finalized the rule that establishes October 1, 2015 as the new implementation date for the healthcare industry’s transition to the ICD-10 diagnosis and procedure coding system. Citing the potential costs along with other factors, the agency determined and ultimately decided that a one year delay was the most reasonable for all stakeholders affected. Click here to read the Centers for Medicare & Medicaid Services (CMS) news release and here to view the actual rule as published in the Federal Register.
Interim rule to implement ICD-10 by October 1, 2015 arrives at the OMB
On Friday, June 13 (coincidence, omen, or both), the Office of Management & Budget (OMB) received the interim rule to implement the ICD-10 diagnosis and procedure code set by October 1, 2015. Interim rules typically have a public comment and review period of 90 days, at which time, the OMB may publsh as originally drafted or modify based on those public comments. Following that time line, it is possible that a final rule for ICD-10 implementation may be published in the Federal Register around the end of September. Assuming the date does not change, that would give NYP and the rest of the healthcare industry one more year to ready itself for the new code set.
As we know, and have experienced, such rules are not written in stone and can be overturned by congressional actions similar to the fourth (yes… fourth) and most recent delay handed down in April of this year through its inclusion in the Protecting Access to Medicare Act of 2014. In the interim, the industry, most notably the Workgroup for Electronic Data Interchange (WEDI) continues to pressure the Centers for Medicare & Medicaid Services (CMS) and the Department of Health & Human Services for more information, more education, and a stronger, more concrete testing and readiness plan to get the larger industry to embrace the transition.
WEDI issues letter to HHS requesting better management of the transition to ICD-10
In a letter to the Secretary of the Department of Health & Human Services (HHS), the Workgroup for Electronic Data Interchange (WEDI) requested improved management of the healthcare industry’s tranbsition to the ICD-10 coding system. Among its 13 points of action, WEDI cited establishing credibility, more transparent communication of its own agencies readiness activities, a well defined testing process with published results, defined and tracked milestones, and generally more positive communication of the benefits ICD-10 will have on the delivery of healthcare. The full letter to the secretary can be viewed by clicking here.