I encourage everyone to read the recently published Heritage Foundation position paper on ICD-10, which can be viewed online at http://www.heritage.org/research/reports/2015/05/the-new-disease-classification-icd-10-doctors-and-patients-will-pay. Most of the paper contains information we have all heard before from various studies (Rand, Nolan, Nachimson).  I do agree that there are ICD-10 implementation costs for physicians that can be burdensome. But implementation for all HIPAA-covered entities is burdensome for all providers, not just physicians. 


For a physician practice, most of the incurred costs involve education and training, and in some cases, system upgrades if the practice does not have an electronic health record (EHR) maintenance agreement – but for most, that cost will be incurred by the EHR vendor. Another notable item in this paper is the notion that physicians should have a choice to use ICD-9 or ICD-10 until a new, less burdensome system is identified.

We have been using ICD-9 as our coding system that supports medical necessity on claims for payment since the late 1970s. ICD-10 contains more codes, but in most cases there is a 1-to-1 translation from the ICD-9 to the ICD-10 codes. Many EHRs have the capability to link the ICD-9 codes to all the applicable ICD-10 codes using mapping files that make selection much easier; some EHRs even have ICD-10 coding calculators to assist with the translation.

It is a fact that there will be a decline in productivity until we become accustomed to the new coding system, which will place an administrative burden on every practice. Physicians who document with specificity today should be able to transition more smoothly. But historically, physicians have documented unspecified conditions with some frequency, and this will put them at risk for audit or payment recoveries following ICD-10 implementation. Most physicians will need to take an intensive look at how they document today, and in many cases they will have to change their documentation patterns for ICD-10. They should have begun this process a couple of years ago. 

Better documentation will improve reimbursement and help providers avoid takebacks from auditors.

There have been various conflicting studies done through the years on the projected costs, productivity losses, and administrative burdens physician practices and hospitals will face following ICD-10 implementation.

However, in this paper, the suggested solution is to abandon the ICD-10 mandate of Oct. 1, 2015 and correct the reimbursement process by delinking the ICD system from our current reimbursement policy and developing an alternate process. I don’t agree that this is the solution, as another system still would mean significant costs, education, and training – and it still will result in productivity losses and administrative burdens.

The final rule mandating ICD-10 was passed in early 2009, and Congress has allowed us two delays already to prepare. We have had six years to get ready, and many practitioners have either ignored the mandate or are banking on another delay.

The other issue with this paper that is concerning is the suggestion that Congress should allow providers to choose which system they use, ICD-9 or ICD-10, until further testing or the conducting of a demonstration project is completed. They are suggesting a three-year period in which to gather this data until a more appropriate system can be developed. How would that not complicate this transition even more? How would payers adjudicate claims for payment? Would this not create utter chaos within our reimbursement system? I think it would be a disaster.

In conclusion, I do agree that some of the issues this paper presents have merit. Documentation is an issue, productivity may decline for a period of time, and adjudication of claims might be delayed, causing shortfalls in the revenue stream. And there are very real administrative burdens associated with the implementation of ICD-10, including a potential need for more qualified staff to perform job functions such as hiring coders.

There also will be a higher level of scrutiny from payers when providers continue to use unspecified codes, and the potential for claims to be denied or suspended for more detailed information or the need to appeal.

But what is the alternative? I don’t believe that another payment system would be simpler, less costly, or create less administrative burden. So much money has already been spent to implement ICD-10, and to delay again at this late date would be even more disastrous to our healthcare system.

My opinions are onward and upward: keep the Oct. 1, 2015 implementation date.


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 is a recognized national speaker, consultant, and American Medical Association (AMA) author who has been working with ICD-10 since 1990. She is the author of “Preparing for ICD-10, Making the Transition Manageable,” “Principles of ICD-10,” and the ICD-10 Workbook, among many other publications written for the AMA. She has assisted hospital systems and physician practices in transitioning and understanding ICD-10 for many years. She is a senior healthcare consultant with Karen Zupko & Associates and a clinical documentation improvement practitioner helping physicians improve clinical documentation among all specialties.

Related Stories

  • ICD-11 is Coming – Take Time to Adjust
    The new classification is designed as a database and has up to 13 dimensions. The World Health Organization (WHO) will be releasing the 11th Revision to the International Classification of Diseases, or ICD-11, this May. The WHO and many of…
  • “Assumptive” Coding for Heart Disease – A Coder’s Perspective
    Official guidance on ICD-10-CM coding raises questions regarding how to document cardiac care. The first step in choosing the proper ICD-10-CM code is reading the medical documentation to identify the diagnosis the provider has documented and confirmed. If there is…
  • Making the Case for Good Auditing
    In this article, the author gives a shout-out to auditors for the good work they do. For those of you who are CEOs, CFOs, medical directors, etc., I would like you to take a moment and read the excerpt below,…