And as I reported earlier this year, one of the top wish list items from hospital CIOs across the nation is regulatory relief. There is just so much free-floating anxiety out there about meaningful use, 5010, and accountable care, that ICD-10 was beginning to feel like the straw about to break the camel’s back.
It’s true that ICD-10 would offer a much richer, and deeper, way of describing procedures and diagnoses. Its predecessor, ICD-9, is notoriously weak on the descriptive front, particularly given the explosion of new procedures during the many moons since I-9 was put in place. No one questions that I-9 is seriously outdated. But as I pointed out in a feature last December, “Here Comes Trouble,” the conversion to I-10 is fraught with peril. One reason is that the codes figure prominently in billing. And so for providers, who are faced with a maze-like array of systems sporting I-9 codes that will need to be remediated, the transition represents a great deal of economic fear.
Ever heard of an “unfunded mandate”? That’s exactly what ICD-10 is. I have yet to meet a hospital or group practice executive who has clearly identified the cost of converting to ICD-10. On the information systems side, they’re not sure if the required upgrades will be part of standard maintenance contracts, or if they will require start-from-scratch installations of compliant billing and clinical documentation software. And on the labor side, they’re not sure how they will find the coders to apply the new codes, how they will train their physicians to document to the level of specificity necessary to uphold the needed level of detail, or how they will cope with an inevitable drop in productivity among both groups during the transition period. And even among proponents of ICD-10, the notion of having a parallel universe of two billing systems in play for some time gives a great deal of pause.
The American Medical Association fired the first—and very loud—shot across the bow when it came out against ICD-10, citing the many other regulatory tasks the industry is coping with. Federal officials have said all along they would not budge on the conversion deadline—which has been postponed one time already. Details are sketchy now, but it appears they are preparing to do just that. This creates two problems. First, every time the government backs off a mandate it as much said was etched in stone, it loses credibility (does anyone even remember the national identifier package “mandated” under the originating HIPAA legislation?). Second, by extending the deadline, the government runs the risk that the many providers already underway in their conversion will bring their efforts to a halt, until they have further clarification.
The only group that seems dismayed by another delay is the American Health Information Management Association, a professional organization of coders that has launched its own ICD-10 training program. AHIMA is well-positioned to address the benefit of the new coding system. Unfortunately, much of the value is, at best, theoretical, while the impact of ICD-10, at worst, would be downright disruptive to the long and multi-faceted food chain of the health care revenue cycle.
My hunch is that the federal delay is not altogether an act of industry altruism, however. I-10 impacts every government payer as well. We know the provider side of the industry is behind schedule on the conversion, according to surveys from WEDI and others. It’s much harder to get a read on payer readiness. But one thing’s for sure—the government definitely does not want to bring industry cash flow to a screeching halt. No one in Washington is saying it, but that is the potential outcome of a rigid ICD-10 conversion policy.