Q&A: On the downside of delaying ICD-10
The possibility of the Centers for Medicare & Medicaid Services delaying ICD-10 sure did cause a ruckus on Tuesday. What began as CMS acting administrator Marilyn Tavenner telling attendees at an AMA meeting that CMS will re-examine the pace of ICD-10 implementation, turned into reports of the agency “signaling” a delay with plenty of physicians stating their support on the record.
But against the backdrop of an industry too far down the ICD-10 tracks to get off now, as the AMA has proclaimed its voting constituency wants, what impact would such a delay have?
Government Health IT Editor Tom Sullivan posed that question to Wendy Whittington, MD, who is CMO of Anthelio Healthcare Solutions. Whittington also discusses tactics CMS might employ rather than pushing back the compliance deadline, and how customers should plan for any changes to the ICD-10 timeline.
Q: Tavenner was perhaps politically vague speaking to the AMA audience, saying that CMS will "re-examine" the ICD-10 timeline, though she mentioned the agency would send more details in the coming days. What are you expecting?
A: One possibility might be a delay in the enforcement of the change similar to the delay in the enforcement of 5010. The fact that she mentioned going through a “rule making process” implies to us that this will take a long time. While I am not in favor of any delay in ICD-10, a short delay would be much more tolerable than a long one. Any delay, however, will just be another reason for healthcare execs to move this important effort to the back burner again. To me, this is similar to a parent making a rule and then not following through. Kids starts to realize that rules don’t need to be followed and deadlines are meaningless.
Q: I don't imagine the AMA alone can really block ICD-10, but what would be the downside for the broader healthcare industry if CMS pushed the compliance deadline back by one year? Or is there a downside to that at all?
A: Pushing the deadline back one year means that we can’t complete all aspects of healthcare reform. Information the government needs to collect to provide effective research on what works and what doesn’t is tied to the more specific information gathered by the ICD-10 codes. Folks who haven’t read ICD-10 don’t understand the benefits of the more detailed coding.
For example, one of the changes in ICD-10 is to better track follow-up care. It is important to healthcare funders and the public to know what specific follow-up care is being given for a particular event or illness. Does the physician actually make changes to the care plan? Or is the physician asking the patient to return just to check in?
Organizations cannot effectively complete strategic planning if rules like this keep changing.
Q: Perhaps engaging the hypothetical here, but if CMS were to delay ICD-10 compliance for one year or even – much like the present HIPAA 5010 "enforcement-free" period – give providers and payers a block of time after Oct 1, 2013 to get their house in order before penalties can be levied for non-compliance or CMS starts rejecting ICD-9 claims straightaway, how would you tell customers to plan for that?
A: We would tell customers to make good use of that time to review their IT systems – not just which systems will be using ICD-10, but how can they optimize those systems to make use of ICD-10 coding to promote better documentation of patient care. For example, under ICD-10, there is a principle of laterality – right or left. If the current IT systems of the hospital or provider can’t handle the “Right or Left” question, we would assist them in making the adaptations now for a smoother transition in the future. This is just one small example of the kind of changes that can be made to accommodate the general principles of ICD-10 and make the transition much smoother.
[See also: ICD-10's Ten-year reign of fear.]