September 11, 2012

Alice’s Return

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Here’s a scenario:

You wake up one morning and look out the window to see that your neighbors all have red grass on their lawns. Must have happened while you were sleeping, right?

Then you chat with your neighbors on either side – and the one across the street – and find that there are lots of advantages to red grass: it’s cooler in the summer, cuts better (even with a dull mower), doesn’t turn brown during droughts (as if anyone would notice) and provides protection against all manner of pests, including bugs, gophers and bureaucrats! Who knew?

So, being the smart person you are – but not really an “early adopter” – you decide to change to red grass, too … in a few years. You make your plans accordingly. You tell the neighbors your plan, you outline exactly how it’s going to look and you declare that anyone who walks on your red grass will be punished. (Very “Dirty Harry” of you.)

And finally, the big day comes. You post your warning signs for those who might actually consider walking on your red grass and you tell everyone that the big “Red Grass Installation Day” will be next Thursday – no question about it, that’s final, no delays, it is what it is.

Then (sigh), on Wednesday you decide that Thursday is just no good for you. It turns out that some of those “walk-on-your-red-grass types” have told you in no uncertain terms that they cannot possibly stay on the sidewalk. They are far too accustomed to cutting across your green lawn, and they know they’ll have to use the sidewalks when the red lawn is installed. So they ask: could you hold off for a little while? “We’re just not ready,” they say, “and we really cannot be ready by Thursday.”

So, you cave, you collapse, give in, acquiesce – and you tell your neighbors that it’s going to be summer 2014 before you can put in that red lawn. Still, you are committed this time; summer 2014 absolutely will be the install date, and nothing is going to change your decision. End of conversation.

Now, you’re smart: I know you are because you’re reading this. And you know very well by now that my “red lawn” is an allegory for ICD-10. The final rule delaying ICD-10 until Oct. 1, 2014 was published on the Centers for Medicare & Medicaid Services (CMS) website in August, and it will have been published in the Federal Register by the time you read this. We all know the handling of ICD-10 by our government has been every bit as lame as the allegory suggests, but does the final rule have anything in it that might pique our interest other than that obligatory new date? In other words, let’s see if there is any good reason why “we’re changing the ICD-10 compliance date to Oct. 1, 2014.” This should require about 208 pages. (Several hours later…)

Ah, of course! The rule is 208 pages because delaying ICD-10 was piggybacked onto two other changes. First was the adoption of the “Health Plan Identifier” (HPID) and the “Other Entity Identifier” (OEID); second was an addition to the NPI rule; and finally there was the change to the ICD-10 compliance date. We won’t talk about the first two items except to give a brief evaluation of each:

HPID: It’s about time! This is the first HIPAA Rule that actually might help providers.

OEID: We weren’t satisfied just numbering the “covered entities;” now we can number everybody! (Where does the line form?)

NPI: Wait: pharmacies will be compelled to order prescribers who don’t have an NPI to get one, and they’ll do so under the authority of federal law? What kind of odd exploit is this? With all that out of the way, let’s talk a bit about the ICD-10 delay and see if, by chance, it’s any more interesting than we all think it is. To begin:

“The compliance date for ICD-10-CM and ICD-10-PCS (is changed) from Oct. 1, 2013 to Oct. 1, 2014.”

There: now it’s official. That line is at the top of page 7 of the final rule.

And here are a few of our beloved bullet points so you won’t need to run out and read a copy right away. (Note: I will not editorialize on CMS’s ability to state the obvious.)

  • “…larger healthcare plans and providers generally are more prepared than smaller entities.”
  • “…a one-year delay … (will) add 10 to 30 percent to the total costs … already spent or budgeted for the transition.”
  • “…(thus) a one-year delay … would cost the entire … industry … $1 billion to $6.6 billion.”

Putting all kidding set aside, this delay happened for three reasons:

  1. The transition to Version 5010 of the Transaction Rule took six months longer than expected.
  2. Providers said other statutory initiatives are stretching their resources.
  3. Surveys and polls said pretty much no one was going to be ready! (What, this was a surprise?)

CMS offered four choices for dealing with the ICD-10 compliance problem, but of all of them, my personal favorite was to blow off ICD-10 and just wait for ICD-11. Of course, that wasn’t taken seriously because it made too much sense.

Oh, and there were some public comments that were remarkably brilliant or uninspired, depending on how you look at things. My favorite of those was (brace yourselves):

How about if we convert the payers and clearinghouses in 2013, and the providers in 2014? That notion is so remarkably poorly thought out, I think that’s where I shall stop.

About the Author

Billy K. Richburg, M.S., FHFMA is HFMA-Certified in Accounting and Finance, Patient Accounting and Managed Care. Bill graduated from the U. of Alaska, Anchorage and earned his M.S. in Health Care Administration from Trinity University, San Antonio, TX. Over a career spanning more than 40 years, Bill has held positions including CEO, COO, CFO, and CIO in hospitals ranging from 75 beds to over 300 beds, and in home health agencies, DME stores, and a home infusion company. Bill is a Board Member of the Lone Star Chapter, HFMA, and is Director of Government Programs for the Revenue Cycle Technologies business segment of MedAssets, Inc. His office is in Plano, Texas.

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Read 6 times Updated on September 23, 2013
Billy Richburg, M.S., FHFMA

Billy K. Richburg, MS, FHFMA is HFMA-Certified in Accounting and Finance, Patient Accounting and Managed Care. Bill graduated from the University of Alaska, Anchorage and earned his MS in Health Care Administration from Trinity University, San Antonio, Tex. Over a career spanning more than 40 years, Bill has held positions including CEO, COO, CFO, and CIO in hospitals ranging from 75 beds to over 300 beds, and in home health agencies, DME stores, and a home infusion company. Bill is a Board Member of the Lone Star Chapter, HFMA, and is Senior Director of Government Programs for the Revenue Cycle Technologies business segment of MedAssets, Inc. His office is in Plano, Texas.