Hospitals, physician groups, payers and the coders who link them together are calling on HHS to delay an industrywide move to a new set of diagnosis codes that has been more than a decade in the making.
In comment letters sent to HHS, prominent hospital, physician and information management associations said they would need a 36-month cushion before switching to the ICD-10 coding structure and to a new generation of the Health Insurance Portability and Accountability Act of 1996 transaction standardstime they say is required to ensure a smooth transition, potentially saving money and manpower.
The American Health Information Management Association, in lockstep with the American Hospital Association, American Medical Association and others, said they want the transition deadline set for Oct. 1, 2012, a full year longer than what the government wants.
Our concern was from talking to providers and vendors of all different sorts that the three-year timeline was necessary, said Dan Rode, vice president for policy and government affairs with AHIMA.
The proposed rule, issued in August, calls for an Oct. 1, 2011 switchover date (Aug. 25, p. 16). Given that the (HHS deadline) is already less than three years away, we didnt feel like we could continue with that date, Rode said.
AHIMA officially made its comments in a detailed Oct. 20 letter to HHS. The letter also pushes for a quick release of a final rule as a way to prompt the industry to move more rapidly while still holding firm to a 36-month timeline.
As time passes, implementation costs will continue to escalate, ICD-9 (Clinical Modification) codes will become completely unworkable, resulting in an inability to create new codes to describe medical advances and new medical knowledge, and healthcare decisions will continue to be made that are based on increasingly unrealizable and inaccurate coded data, the letter states.
The HHS rule would amend HIPAA and require all HIPAA-covered organizations to switch to ICD-10 CM codes for diagnosis and the ICD-10-PCS (procedure coding system) codes for inpatient hospital procedures. The new code sets would replace the ICD-9 series.
Taken together, the codes dictate almost all transactions, whether its a claim being sent to a payer, remittance advice or request for eligibility. A recent study, funded in part by the AMA, found that the implementation of the new codes under the HHS deadline could cost some large practice groups close to $2.73 million, though more commonly it would run anywhere from $83,000 to $285,000.
Some of the costs would be one-time only, such as adding and training staff, upgrading IT systems and insurance plan review.
The coding switchover, first proposed more than a decade ago, would expand the code sets to 87,000 possible codes from the current 13,000 options. To do so, however, first requires another significant transition, the adoption and implementation of a new HIPAA transaction platform, which many fear will be a heavy lift for the industry.
In a letter dated Oct. 21, the AHA told HHS that the rollout of the new codes could have a significant financial effect on its members. During the switchover, hospitals will likely have to change certain software interfaces, field-length formats on screens, report formats and layouts and other technical aspects, the letter states.
Hospitals will bear the financial burden associated with software changes as well as possible hardware upgrades, the letter, signed by AHA Executive Vice President Richard Pollack, states. While in the end the migration will benefit the nations healthcare system, the hurdle for hospitals is the initial investment needed to prepare for these changes.