Armed with a new study showing that anticipated ICD-10 compliance costs for physicians may have tripled since a similar study in 2008, the American Medical Association is asking the federal government to reconsider the mandate to adopt the code sets.
AMA commissioned the consulting firm Nachimson Advisors to estimate physician practice ICD-10 costs in 2014. The consultancy also did the 2008 report, which estimated an $83,290 cost for a typical small practice, $285,195 for a medium practice and $2.7 million for a large practice. In 2014, the cost estimates are $56,639-$226,105 for a small practice, $213,364-$824,735 for a medium practice and $2 million-$8 million for a large practice.
The new study takes into account the upgrade or purchase of new practice management software, as well as having electronic health records system certified for the 2014 Edition of meaningful use. It also expands expense categories that were not considered in the 2008 study, such as ICD-10 testing.
In a Feb. 12 letter to HHS Secretary Kathleen Sebelius in which it asked for reconsideration of the ICD-10 mandate, the AMA says it does not discount the value of ICD-10 data for public health surveillance, research and other data analytics initiatives. But it questions the logic of adopting the code set at this time. By itself, the implementation of ICD-10 is a massive undertaking, according to the letter. Yet, physicians are being asked to assume this burdensome requirement at the same time that they are being required to adopt new technology, re-engineer workflow and reform the way they deliver care; all of which are interfering with their ability to care for patients and make investments to improve quality.
The vendor community isnt ready enough to support physician migration to ICD-10, the AMA contends. Less than half of physicians expect their practice management vendor to deliver an ICD-10 compliant upgrade, the association told Sebelius, and Stage 2-updated EHRs also are not being delivered in a timely manner.
Further, Medicares own role in ICD-10 readiness has not been stellar, the AMA reminds Sebelius. A pilot program last summer found an accuracy rate of only 63 percent among facility coders using ICD-10. And Medicare has not committed to end-to-end testing. If it is not possible to conduct this type of testing with all physicians, then we strongly urge Medicare to conduct true end-to-end testing with at least 100 different physician practices of varying sizes and specialties. Any experience gained through such a testing exercise should be used to inform CMS decision to adhere to the October 1, 2014 deadline.
The AMA also asks for a flexible Medicare advance payment policy to aid physicians who may face financial crisis because of delayed reimbursement after the compliance date. Further, with a claims attachment standard not forthcoming in the near future, the association is asking for a policy change in Medicares claims adjudication process.
Medicare has stated in numerous public forums that the move to ICD-10 is expected to result in fewer requests for attachments and additional information to substantiate claims before physicians can be reimbursed, according to the letter. We urge CMS to formally adopt a policy for Medicare that states when the most specific ICD-10 code is submitted by a physician no additional information will be required to adjudicate the claim, particularly in the absence of an attachment standard.
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