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Updated on: March 16, 2016

They Tore Out My Heart and Stomped That Sucker Flat

Original story posted on: April 7, 2014

While there are those who have vigorously campaigned for the delay of ICD-10 due to fears of risk to physician practices, costs, financial disruptions, lack of meaningful testing, etc., there are many others who feel just like the title of this article indicates. It seems that most in the latter group fully recognize the investment and risks associated with ICD-10 and are not without grave concerns. It has simply been a choice to prepare for ICD-10 in ways that mitigate those risks to the extent possible and maximize the likelihood of, if not success, at least the absence of failure.


Like many in our industry, I have spent the last five years preparing for Oct. 1, 2013 and then Oct. 1, 2014. My company has worked with our physicians to help them budget and provided education and information to improve clinical documentation. We have trained all of our coders and are practicing dual-coding to mitigate production decreases. We have invested in risk assessments, financial planning, staffing needs assessments, system upgrades, new software, programming, and testing. In fact, we just completed true end-to-end beta testing with our state Medicaid program. And we are just one small company out of many that have invested as much or much, much more so we can be as prepared as possible for the implementation.

Certainly there are real risks and real costs to the implementation of ICD-10 that will become increasingly evident this year, and we should not lose sight of those facts. But will the risks and costs grow significantly larger with another delay? If the one-year delay until October 2014 was insufficient, will one more year make a difference? If we consider the potential ramifications of another delay, we are duty-bound to give the following issues careful thought.

  1. Credibility has been lost. Every authoritative organization and government agency has been adamant that there will be no delays, first in 2013 and in 2014 until today. Although the first delay was by Centers for Medicare & Medicaid Services (CMS) Administrator Marilyn Tavenner and the most recent delay was by congressional vote, will anyone believe it’s really going to happen in 2015, if ever? It is certainly doubtful.

  2. Since doubt or outright disbelief about implementation will be the new norm, resources are sure to be diverted away from ICD-10 preparation, staffing, coder training, programming, and testing. The cost has already been astronomical, with no foreseeable return on investment. I cannot think of very many organizations that will continue to throw away good money. It is also doubtful that those organizations will be quick to reinvest based on any announcement that “we really mean it” the next time.

  3. There will be a negative impact to other programs and initiatives. Quality payments, electronic health record (EHR) adoption, fraud initiatives, comparative data, to name a few, all will be affected. What costs will those delays incur?

  4. What will it cost to try to pick up where we are stopping? Momentum has already been lost, knowledge gained but not used will be lost, experts will leave, staff will need to be rehired and retrained, risk assessments will need to be redone, resources and budgets will need to be reallocated, and the list goes on and on. In many ways, we will be starting over and incurring all the costs that go along with implementation all over again. If physicians and the industry were concerned about costs now, how will they possibly absorb even larger ones?!

If any payer, entity, organization, vendor, provider, physician, or other critical trading partner was unable to prepare over the many years we have had, it is extremely doubtful that they will be ready by Oct. 1, 2015. Will there be a need to add one more year then also? Will the recommendation become “just wait until ICD-11 arrives” and then we start the whole cycle over again? These recent events have been very disappointing.

If the above concerns prove to be valid, every added year means that more and more will not be ready – not next year, and maybe not ever.

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.
Holly Louie, RN, BSN, CHBME

Holly Louie is the compliance officer for Practice Management Inc., a multi-specialty billing company in Boise, Idaho. Holly was the 2016 president of the Healthcare Business and Management Association (HBMA) and previously chaired the ICD-10 Committee. Holly is also a national healthcare consultant and testifying expert on matters related to physician coding, billing, and regulatory compliance. She has previously held compliance officer positions in local and international billing companies. Holly is a member of the ICD10monitor editor board and a popular guest on Talk Ten Tuesdays.

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