Executive vice president and CEO James Madara has sent a letter (48K PDF download) to the acting administrator for the Centers for Medicare and Medicaid Services (CMS), Marilyn Tavenner that asks for the delay and a few other things. Things such as:
- A cost-benefit analysis of the administrative and financial impact of ICD-10 implementation.
- A search for an alternative to the ICD-10 code set.
- If no alternative is found, then they want ICD-10 implementation postponed indefinitely.
- A reduction of burden imposed by "multiple health IT programs."
This seems to be a more simple, direct version of the Medical Group Management Association (MGMA) strategy to kill ICD-10 implementation. The AMA isn't even pretending to like it.
When explaining the need to find an alternative, Madara writes "While a number of other countries have implemented ICD-10, they have done so with a modified version of the code set and often with substantial government support. "
Am I missing something? Isn't ICD-10-CM a modified version of the code set? And that's why Madaras is able to complain about the 68,000 diagnosis codes that will create such a massive administrative and financial burden.
Also, there is a sentence so important that Madara marked it in bold:
"If stakeholders cannot reach consensus on this matter during this two-year delay period, then the move to ICD-10 should be postponed indefinitely."
This is confusing to me. Because if CMS spends two years searching for a better alternative and doesn't find one, the AMA conclusion is that we should forget about ICD-10 implementation. Other people may interpret the lack of alternative as a sign that's the best we have and we should run with it.
And if stakeholders (regulators, physicians, healthcare information technology professionals, medical coders, administrators, politicians) do reach consensus on an alternative, how in the heck is the CMS going to justify ICD-10 implementation?
I guess it's possible that stakeholder consensus could conclude that ICD-10-CM/PCS is the best solution. But in the modern political environment, consensus is an extinct creature.
I get the administrative and financial burden complaints. This isn't going to be easy. I've spent a lot of time this past year writing about how hard it's going to be. And the proposed rule has drawn comments from people identifying themselves as physicians who spend too much time on coding as it is. So they're not going to be happy with ICD-10-CM/PCS or any alternative in 2015.