The Challenges of ICD-10 Implementation

On October 1, 2013, the entire US healthcare system will shift from ICD-9 to ICD-10. It will be one of the largest, most expensive and riskiest transitions that healthcare CIOs will experience in their careers, affecting every clinical and financial system. It's a kind of Y2K for healthcare.

Most large provider and payer organizations, have a <a href="/directory/icd-10" target="_blank" class="directory-item-link">ICD-10 project budget of $50-100 million, which is interesting because the ICD-10 final rule estimated the cost as .03% of revenue. For BIDMC, that would be about $450,000. Our project budget estimates are about ten times that.

CMS and HHS have significant reasons for wanting to move forward with ICD-10 including

1) easier detection of fraud and abuse given the granularity of ICD-10 i.e. having 3 comminuted distal radius fractures of your right arm within 3 weeks would be unlikely

2) more detailed quality reporting

3) administrative data will contain more clinical detail enabling more refined reimbursement

Large healthcare organizations have already been working hard on ICD-10, so they have sunk costs and a fixed run rate for their project management office. At this point, any extension of the deadline would cost them more.

Most small to medium healthcare organizations are desperate. They are consumed with meaningful use, 5010, e-prescribing, healthcare reform, and compliance. They have no bandwidth or resources to execute a massive ICD-10 project over the next 2 years.

Vendors have told me such things as "I have been amazed at how much we (and our third-party partners) are spending on getting prepared for ICD-10 – and it's not what you would expect (extending data tables, new code lookup tools, etc.) It's a whole host of clinician assistance tools, new documentation workflows, new kinds of provider-facing decision support to maximize coding revenue while guarding against RAC audits - all simply for billing!"

In my CIO role, not any state or federal role, I will continue to listen to concerns about ICD-10, sharing them broadly on my blog and with government leaders who will listen.

The Wall Street Journal recently published an article about the granularity of ICD-10.

One of my staff posted this response, which is very thoughtful: