September 8, 2014

The Government That Cried Wolf

By D’Arcy Guerin Gue

In the classic Aesop’s fable, the young shepherd boy cried wolf three times. The first two times, there was no wolf. The third time, there was a wolf, the townsfolk didn’t believe the boy, and he lost part of his flock.

Today, the healthcare industry’s perspective of ICD-10 is very much the same. The government has “cried ICD-10” twice already. In 2013 and 2014, many of us (the “townspeople,” so to speak) raced to implement the new coding set only to have either the Centers for Medicare & Medicaid Services (CMS) or Congress back down on the conversion deadline. The latest, third deadline now has been confirmed by CMS as Oct. 1, 2015, and more than a few providers are still responding like the townspeople – rolling their eyes with doubt.

Admittedly, in the original fable, deliberate lies caused the town’s loss of confidence in the boy. While CMS and Congress certainly can’t be accused of lying about ICD-10, what do the delays and resulting confusion say about the credibility of our government?

This issue is the crux of today’s environment of distrust and disbelief in the new Oct. 1, 2015 ICD-10 deadline. Providers are concerned that their efforts and dollars may be wasted yet again. They point to the messy politics in Washington, D.C. and long-term resistance to ICD-10 by powerful interest organizations such as the American Medical Association.

In the last month, we’ve talked to a dozen hospital leaders, some of whom are starting to renew their ICD-10 conversion efforts and some who claim that they’ve washed their hands of ICD-10. Notably, all of them share a perspective that can be summarized as a variation of the following: “When the latest delay was passed by Congress, we breathed a sigh of relief. We were behind and we knew it. But we didn’t know what was coming next with ICD-10, and CMS wasn’t talking. We put our ICD-10 project work on hold, and refocused on projects that needed more urgent attention, like Meaningful Use Stage 2.”

Now that it’s time to re-energize ICD-10 efforts, we are seeing signs of a lasting crisis of confidence in CMS’s ability to keep ICD-10 on track. However, despite the past delays, the fact is that ICD-10 has to happen – and soon.

Here’s why:

Why ICD-10 Will Be Implemented:

Much-Needed Global Healthcare Management

You’ve all heard it: the U.S. is the only industrialized nation not currently using an ICD-10-based classification system for disease coding. ICD-10’s exceptional granularity in capturing diagnoses and procedures details is essential to the tasks of recording and reporting healthcare data accurately (unlike with ICD-9). Without joining the ICD-10 worldwide bandwagon, the U.S. will remain unable to fully engage in global efforts to gather and share data regarding healthcare, including infectious diseases. Without ICD-10-based communications, we cannot provide authentic leadership in international quality care improvement and development of best practices. And finally, without ICD-10 our population health research capabilities are increasingly superficial, and our contributions to global health population management are compromised.

Better Management of Healthcare Costs

ICD-10 coding requires better documentation by physicians and other clinicians – even if understandably, this is not their favorite task. Nevertheless, more exact and complete reporting will create measurably better understanding of diseases and procedure-related complications, plus better tracking of care outcomes. The result, desired by almost everyone, will be major progress in reducing healthcare costs through improved trend and cost analysis, improved performance measurement of providers, and more precise evaluations of the efficacy and cost effectiveness of new medical procedures.

In addition, with better mapping to SNOMED CT, ICD-10 will facilitate the implementation of money-saving technologies such as computer-assisted coding (CAC). Its robust data set also allows for more accurate development and implementation of evidence-based medicine and enhanced search ability. All of this enables opportunities for interoperability between systems and organizations – a central goal of federal healthcare initiatives such as Meaningful Use.

Existing High Levels of ICD-10 Readiness Across the Industry

While many small healthcare organizations were relieved when Congress postponed the deadline this year, large hospitals and multi-entity systems were not. Neither were payors. They had invested one to three years and millions of dollars in ICD-10 preparations, and felt ready to meet the 2014 deadline.

Most of these organizations did not stop in their tracks upon the latest postponement, however. According to an American Health Information Management Association (AHIMA) survey conducted with the e-Health Initiative in June, they have continued to move ahead judiciously, applying extra time and efforts toward clinical documentation improvements, workforce training, and partner testing.

The fact is most hospital organizations want to finish up with ICD-10 and move on.

Why the New Oct. 1, 2015 Deadline is Real:

Healthcare Reform and Meaningful Use Share a Trajectory

The major goals of the Patient Protection and Affordable Care Act, Meaningful Use incentives, and most healthcare legislation are moderating costs, improving care, and enabling patients to manage their healthcare options. Congress and the president have already bet and invested strongly on the expansion of healthcare IT for achieving these goals, and the power of ICD-10-based data reporting is integral to that effort.

Waiting for ICD-11 is Unrealistic

The World Health Organization (WHO) plans to introduce the ICD-11 code set in May 2017. The introduction does not translate into a slam dunk. After ICD-11 is released, it will take years to develop the clinical modifications and associated procedure coding standards, and then several more years to implement the code set. The U.S. government and most healthcare organizations will not wait six-plus years to reap the benefits of a more detailed code set.

Another ICD-10 Delay Is Highly Unlikely

CMS has committed to a fiscal year-based strategy for ICD-10, and it has neither the money nor the time to change this. It needs to transition from ICD-9 to ICD-10 on the first day of the fiscal year to eliminate having to cope with two code sets in the same fiscal year. The number of government programs that are driven by coded and billed data (Medicare, Value-Based Purchasing, and any program driven by quality-based data) makes the logistics of developing systems, processes, and policies to properly span fiscal years virtually impossible. CMS has clearly indicated that holding Congress to its one-year delay is the best option for minimizing costs and impacts to the industry.

What Should Providers Do to Renew Their ICD-10 Momentum?

Once the reality that Oct. 1, 2015 is the final final ICD-10 deadline takes hold, the stage will be set for a renewed focus on ICD-10.

For now, I recommend that providers treat ICD-10 and 2015 as a “new” initiative, with a completely redesigned timeline to reflect the change in dates. In addition, ICD-10 project leaders should start rebuilding organizational buy-in by focusing in areas where there is benefit available today. A good example of such low-hanging fruit is working toward provider documentation improvement. More accurate coding results will improve care, reduce denials, provide opportunities for enhanced reimbursement, and in the long term, help mitigate disruption and unnecessary costs when ICD-10 is “turned on.”

To get critical momentum back, provider organizations also need to focus on a deliberate communication strategy. The core message should be plain and simple: ICD-10 is real this time. The world needs it, and the big players are now forewarned – they won’t let ICD-10 disintegrate again into a false alarm.

About the Author

As a co-founder of Phoenix Health Systems, D’Arcy has had leadership roles in the growth of the company. Currently, she leads overall corporate administration, marketing and industry relations, services development, human resources, and knowledge management. She has led various strategic initiatives, including the development of ICD-10 services, HIPAA-based security and privacy compliance tools, and online education programs.

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Disclaimer: Every reasonable effort was made to ensure the accuracy of this information at the time it was published. However, due to the nature of industry changes over time we cannot guarantee its validity after the year it was published.