ICD-10 comments suggest longer delays, new code systems

The end of the comment period on the U.S. Department of Health and Human Services’ (HHS) proposal to delay the compliance date for switching to International Classification of Diseases, 10th Edition, diagnosis and procedure codes (ICD-10) on May 17 spurred several comments, suggestions, and criticisms from industry leaders and stakeholders.

The comments center on HHS’ proposal to delay the ICD-10 implementation deadline from October 1, 2013, to October 1, 2014. But some groups want an even longer delay.

The American Medical Association (AMA) says physicians are overwhelmed with the administrative and financial burdens the transition to ICD-10 will cause, especially in light of numerous other program implementations with which they must comply and proposed Medicare physician payment cuts. The AMA is asking the Centers for Medicare and Medicaid Services (CMS) to consider extending the deadline for ICD-10 implementation to October 1, 2015, so that CMS can conduct a cost-benefit analysis for the new system and assess possible alternative code sets. The AMA notes that other countries that have adopted ICD-10 already use a modified code set.

“If stakeholders cannot reach consensus on this matter during the 2-year delay period, then the move to ICD-10 should be postponed indefinitely,” says James L. Madara, MD, AMA executive vice president and chief executive officer.

The Medical Group Management Association (MGMA) submitted similar comments, asking for a cost-benefit analysis and evaluation of alternative systems, staggered implementation dates, and a pilot testing program. The MGMA notes that ICD-10 implementation is expected to cost small physician practices roughly $83,000 and large practices up to $2.7 million, with the highest costs coming from increased documentation. Other countries that have implemented ICD-10 used smaller code sets, gave government funding to providers to help cope with the transition, and offered pilot tests of the program, according to the MGMA.

The American College of Physicians (ACP) offered yet another suggestion to CMS, going so far as to recommend a completely different coding system-Systemized Nomenclature of Medicine–Clinical Term (SNOMED-CT)-rather than ICD-10.

At the least, the 1-year delay is necessary to ease the implementation burden posed to providers.

“Physicians are caught in a dilemma of having to simultaneously implement a multitude of healthcare reform initiatives, including a health transaction format, electronic prescribing, Physician Quality Reporting System, meaningful use, accountable care organizations, Patient-Centered Medical Homes, and electronic health records,” says Michael H. Zaroukian, MD, PHD, FACP, FHIMSS, chairman of ACP's Medical Informatics Committee.

The College of Healthcare Information Management Executives supports the proposed delay but cautions against further delays, which it says would disrupt ongoing conversion efforts and increase the cost of switching to the new system.

The American Health Information Management Association recommends that the ICD-10 implementation deadline not be delayed.

CMS has not said when it will issue a final rule on the delay.

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