It has been yet again a roller coaster ride with the potential threat of another ICD-10 delay. There are valid arguments on both sides to proceed with or delay the introduction of the new coding set. But think about this: there has been a great deal of money spent on ICD-10 already. How do vendors, hospitals, physician groups, and others recoup the loss of money spent getting ready if another delay occurs? How do we train the physicians, hospitals, and coders when it seems like we have been on this roller coaster ride for several years? Will the industry pay attention if there is another delay?

 

Let’s take a look at what has been happening since the beginning of February. On March 4, the American Medical Association (AMA) sent a letter to the Centers for Medicare & Medicaid Services (CMS) and the U.S. Department of Health and Human Services (HHS) voicing specific concerns; the letter was signed by most of the state medical associations and several key specialty societies.  One of the most key issues being voiced not only by these societies and associations, but by many others in the healthcare industry as well, is the concern over receiving payment during the transition. Acknowledgement testing only covers the claims that will initially be accepted through the claims processing system; it does not provide information on how claims will process from acceptance to payment (which will potentially impact payment to hospitals and physicians). Some of the other concerns include the following points:

1.  End-to-end testing conducted thus far, while largely successful, has been based on a broad overview of claims received, with an 81 percent acceptance rate (which is below the overall current average of 95-98 percent). However, this could be due to errors from the providers sending test claims. The AMA is requesting more detailed end-to-end testing, separated by:

    • Type of provider
    • Size of provider
    • Number of claims by each submitter
    • Percentage of claims successfully processed
    • Details about problems

2.  The ability to collect accurate, quality data related to quality measures is up in the air due to conflicting timelines for PQR (physician quality reporting) and meaningful use reporting periods (Jan. 1 to Dec. 31, with ICD-10 beginning Oct. 1). This will create additional reporting issues with ICD-9 and ICD-10. The AMA is concerned, as CMS has not addressed its plans to calculate quality performance metrics during this period.

3.  The other issue related to quality measures is their anticipated effects on value-based modifier measures (VBMMs), which could alter performance periods and how measures are scored. The VBMM compares how providers perform. Commercial payers have quality reporting measures that may impact reimbursement, which could be affected by changing from ICD-9 to ICD-10.

4.  One of the most significant issues is cash flow interruption, which could be devastating for a small or even a larger group practice. Payers, including CMS, have not shared any contingency plans with the industry in the event that payment disruption occurs. The AMA is asking CMS for advance payments to physicians who experience financial hardship during the transition.

5.  There is a concern that many electronic health record (EHR) vendors may not be ready for ICD-10 by Oct. 1, 2015. It is difficult to determine which vendors are ready and which are still working toward readiness. The AMA is asking that this information be made available.

6.  The last concern is that the specificity of the coding might create triggers for audits unnecessarily. The AMA wants a confirmation from CMS that claims would not be audited just for code specificity and that CMS contractors will be prohibited from auditing based on code specificity.

So where does this leave us now? U.S. Representative Pete Sessions (R-Texas), chairman of the House Committee on Rules, may seek support from colleagues in Congress to draft language that would delay the implementation of ICD-10. Every bill drafted must pass through the Rules Committee before going to the House. The Rules Committee considers all bills reported from policy and fiscal committees and determines whether, and in what order, to schedule their consideration on the floor. The Rules Committee also reviews, adopts, and schedules consideration of floor resolutions.

The chairman will decide if the ICD-10 legislation should be taken to the House floor. There are also rumors floating around Congress that an ICD-10 delay might be thrown into another bill ready for passage or the legislation annually affecting the sustainable growth rate (SGR). The next three weeks will be a critical time of watching and waiting to see what happens next. To me this is becoming more like a bad reality television show. The American Health Information Management Association (AHIMA) is starting another Twitter rally March 12 in a bid to head off another delay.

The healthcare industry cannot afford another delay. As one of the testifiers stated in the recent congressional hearing on ICD-10, we either need to move forward and implement ICD-10 on Oct. 1, 2015, or just cancel ICD-10 altogether. I think many in the healthcare industry are feeling that sentiment right about now. With all of us trying to get ready for the implementation of ICD-10, the threat of another delay looming threatens to paralyze us.

Another delay would be a potential death sentence for ICD-10. Even if there is another one- or two-year delay, there will always be resistance in the implementation of ICD-10. Even if we cancel ICD-10 entirely, we will still be facing the facts that ICD-9 is outdated, lacks specificity, and does not really paint a true picture of the patient’s condition (which can cause substantial errors in treatment). The United States has always been a leader when it comes to healthcare, but we are lagging behind when 38 countries have adopted ICD-10 and have been using it for years.

So in conclusion, I encourage you to join the Twitter rally with AHIMA on March 12 – and let’s finally get ICD-10 implemented.

 

Deborah Grider, CPC, CPC-H, CPC-I, CPC-P, CPMA, CEMC, CCS-P, CDIP, Certified Clinical Documentation Improvement Practitioner

Deborah Grider has 34 years of industry experience and a recognized national speaker, consultant and American Medical Association Author who has been working with ICD-10 since 1990 and is the author or Preparing for ICD-10, Making the Transition Manageable, Principles of ICD-10 and the ICD-10 Workbook, Medical Record Auditor, and Coding with Modifiers for the AMA.  She is a senior healthcare consultant with Karen Zupko & Associates.  Deborah is also the 2017 American Health Information Management Literacy Legacy Award Recipient. She is a member of the ICD10monitor editorial board and a popular panelist on Talk Ten Tuesdays.