The proposed switch to ICD-10 code sets from ICD-9 represents a huge information technology challenge for the U.S. healthcare system at an estimated cost in the billions of dollars, according to a formal notice of proposed rulemaking issued by HHS.
Reactions to the notice released Aug. 15 are mixed. Some organizations praise the initiative while others protest the aggressive staging of the rollout and its compliance deadlines, which they say are unattainable.
The proposed rule would amend the Health Insurance Portability and Accountability Act to require all HIPAA-covered entities to switch to the International Classification of Diseases, 10th Revision, Clinical Modification, or ICD-10 CM, codes for diagnosis and the ICD-10-PCS (procedure coding system) codes for inpatient hospital procedures, according to an HHS announcement. The new codes would replace the ICD-9 series, still in use in the U.S., but long since abandoned elsewhere.
Weve very excited, said Sue Bowman, director of coding policy and compliance for the Chicago-based American Health Information Management Association. Weve been working on trying to get ICD-10 implemented for a number of years now, so were very happy to have it come to fruition.
HHS also issued a separate proposed rule to adopt an updated family of data transmission standards by the Accredited Standards Committee called ASC X12 Version 5010, which are needed to carry the ICD-10 codes. The compliance deadline for the ICD-10 code conversion is Oct. 1, 2011; for 5010, April 1, 2010.
The movement to the ICD-10 will likely touch every provider who submits diagnostic codes and every payer that processes healthcare claims, HHS said. But the enhanced codes will allow clinical IT systems to record a much more specific and rich diagnosis than ICD-9 codes for use in pay-for-performance programs. The conversion also will better enable the U.S. to run biosurveillance programs and fight medical billing fraud, the government said. According to HHS, the ICD-10 codes contain more than 155,000 codes and can describe far-more-complex diagnoses and procedures than the ICD-9 series, which has about 17,000 codes.
The implementation costs, however, will be high upfront and hard to estimate while the benefits from the investment, although thought to be even higher, will be protracted, diffused and not always returned to the investor. HHS estimates that the net benefit to society for implementing ICD-10 ranges from $47 million to $5.9 billion, but said its primary estimate was $2.3 billion through 2023.
Bowman said its too early for AHIMA to form an opinion on whether the 2011 deadline is doable.
Some in the industry are taking a positive or wait-and-see approach. George Arges, senior director of the health data management group at the American Hospital Association, said the switch is a serious undertakingbut its an investment in a change that should endure for some time thereafterso amortizing these costs over a 20-year period makes it less onerous. Arges said, It is doable in the 2011 timeframe, but adds that standards like these will always be going through change and improvement.
And Jayne Hart Chambers, senior vice president of strategic policy at the Federation of American Hospitals, said the change is needed. We really need the robustness of ICD-10 to make some of the quality measures we want work. The fact that we got the secretary to actually say, OK, lets do regulation, is a wonderful thing, she said, referring to HHS Secretary Mike Leavitt. The FAH has been part of a coalition with the AHA and other healthcare groups pushing for ICD-10.
Regarding the 2011 implementation deadline, however, My gut tells me its probably an ambitious goal, Chambers said.
Others are even more pessimistic. Robert Tennant, senior policy adviser for the Medical Group Management Association, represents that group within a rare coalition of providers and payers who see the HHS pace for ICD-10 and its timing with the ASC X12 5010 implementation as laying out a framework for disaster.
Weve lived through the HIPAA world, and we dont want to make the same mistake over and over again, Tennant said. Why the government thinks it can transition to 5010 in 12 months is beyond my comprehension.
The MGMA along with the American Medical Association, the American Osteopathic Association, a number of medical specialty societies and the Blue Cross and Blue Shield Association, submitted a strongly worded letter to Leavitt advising HHS to pilot test ICD-10 and ASC X12 5010, as well as roll out and debug 5010 well before implementing ICD-10.
Their advice leaned heavily on recommendations to Leavitt from the National Committee on Vital and Health Statistics, which has held multiple hearings on ICD-10 over the years. They summarily rejected some of the key recommendations of NCVHS, Tennant said. Theyre in a rush because the administration is coming to an end. Were very concerned.