I listened in via the Web on the Wednesday U.S. House of Representatives Energy and Commerce Committee Health Subcommittee hearing on examining ICD-10 implementation. The subcommittee chairman, Joseph Pitts of Pennsylvania, opened the meeting with a brief overview of ICD-10. Testimony was presented by Carmella Bocchino, executive vice president of America’s Health Insurance Plans; Richard Averill, director of public policy for 3M Health Information Systems; Kristi Matus,  chief financial and administrative officer for Athena Health; Sue Bowman, director of coding policy and compliance for the American Health Information Management Association (AHIMA); William Terry, MD, representing the American Urological Association; John Hughes, MD, professor of medicine at the Yale School of Medicine; and Edward Burke, MD, who practices internal medicine in rural Missouri.

 

Prior to attending the hearing, I downloaded and read all of the testimony provided. While all speakers agreed that ICD-10 presents some unique challenges, not all who testified agreed that there should be no more delay – the lone exception was Dr. Terry. All of those testifying shared comments about the added burden of delaying ICD-10 from the perspective of cost, with some noting that many practitioners are waiting for someone to tell them ICD-10 will not be delayed. Most agreed that implementation of ICD-10 is long overdue; Matus stated that we need to either move forward with implementation of ICD-10 on Oct. 1, 2015 or cancel it altogether. I tend to agree with that. There has been too much back and forth so within the industry, meaning that many healthcare providers are skeptical about whether ICD-10 will really happen at all. All of those who testified also agreed that repeated delays result in uncertainty, increase costs, and create fear in the industry – meaning above all that ICD-10 must not be delayed again. 

After testimony was delivered, congressional representatives were given the opportunity to ask questions. Pitts stated that he supported no further delays in ICD-10 implementation, asking all who testified if the industry was ready to go forward with ICD-10 – all agreed that the industry is ready, with the exception of Dr. Terry. Terry noted that he does not oppose ICD-10, but that he feels implementation should be accomplished gradually and not all at once. He also indicated that it would be more beneficial (especially for small practitioners) to dual code for about a year before being held fully accountable for achieving correct coding. Furthermore, Terry indicated that many small practices could be driven out of business with the current implementation strategy. 

According to the testimony, some of the anticipated benefits of ICD-10 included:

  • More specificity in documentation, with ICD-10 allowing for enhanced support of better patient outcomes, safety measures, and quality of care;
  • Improved communication among providers, especially with use of an electronic health record (EHR);
  • Improved data for tracking new diseases and progression of diseases;
  • Assistance with identifying new technology and procedures that will assist with research;
  • Assistance with clinical documentation improvement;
  • Reduction of the burden of payor requests for additional documentation to process claims;
  • Electronic tools and apps available for smart phones to assist with coding;
  • Help in detecting and preventing fraud and abuse;
  • Technology that will make the comprehensive coding system more manageable; and
  • More accurate reimbursement.

Some of the concerns with moving forward with ICD-10 include:

  • Cost, particularly for small providers tasked with implementation and training of staff;
  • Additional documentation required for ICD-10, which will cause a reduction in the number of patients a practitioner can treat due to time constraints;
  • The notion that MS-DRGs will not be kept up to date;
  • A feeling that mandatory implementation should be at the discretion of the provider;
  • Fears that more studies should be conducted and a new implementation strategy developed;
  • Lack of incentives by the Centers for Medicare & Medicaid Services (CMS);
  • The fact that many physicians will chose to retire early, causing a shortage of practitioners, particularly in rural areas; and
  • Accounts receivable days increasing from 20-40 percent, which will extend days in AR, causing a need for bank loans to keep practices afloat.

Members of the subcommittee asked very good questions of the testifying panel, and while members of the subcommittee agreed that ICD-10 must move forward, they appeared to be split on whether there should be an additional delay or further studies conducted. The concerns included cost, how it will affect patient care, the effects on small practitioners, and if CMS and payors are truly ready for a smooth transition. Follow-up questions by the subcommittee for the panel members who testified must be submitted by Feb. 26. So we are all still waiting for their decision. 

Do I think there will be another delay? I really thought that after the testimony it would become clear, but I am not certain we will not have another delay. What I can say is that I hope the subcommittee weighs in on the benefits of moving to ICD-10, the money spent thus far by all in the healthcare community, the added cost for another delay, and that continuing to prolong ICD-10 will cause more confusion and turmoil in the industry, on top of the so many other changes we have experienced in the past 10 years. The healthcare industry cannot afford another delay. As Matus stated, we either need to move forward and implement ICD-10 on Oct. 1, 2015 or just abandon it altogether. 

However, if we cancel ICD-10, we will still face the problems that ICD-9 is outdated, that it lacks specificity, that it does not really paint a true picture of the patient’s condition (which can cause substantial errors in treatment), and lastly, that the United States has always been a leader in healthcare, but we are lagging behind when 38 countries have adopted ICD-10 and have been using it for years.

So, where do you go from here? I strongly urge you to keep moving forward with your implementation timeline. If you have not started getting ready with system upgrades and education and training, begin now. Don’t take a wait-and-see attitude, as it could be costly to your practice or organization. CMS has provided many free resources on its website: http://www.cms.gov/icd10. The agency also offers training modules, which benefit physicians. There are also many training opportunities for ICD-10 nationally to assist with readiness.

We have less than eight months to get ready for ICD-10, and time is quickly passing.

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.