One CMIO's ICD-10 solution

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 - CMS to Mount End-to-end ICD-10 Testing for Some Providers

Despite a vigorous letter-writing campaign by some state medical associations, it appears that the deadline for the implementation of ICD-10 will remain Oct. 1, 2015—for now, anyway.

The hope on the part of organizations like the American Medical Association and state medical associations in Texas, New York, and Florida, was that language could be inserted into federal legislation that could delay ICD-10 implementation.

But according to the American Health Information Management Association (which is part of a coalition advocating against any further ICD-10 delays) the $1.1 trillion “crominibus” bill filed in the House of Representatives this week does not include any language delaying the implementation of ICD-10 beyond next October.

And yesterday, the House Energy and Commerce Committee and the House Rules Committee issued a joint statement on ICD-10, which stated that the Energy and Commerce Committee has been working with the Centers for Medicare & Medicaid Services (CMS) to ensure the Oct. 1, 2015 implementation date is achieved, and is prepared to have a hearing on the issue in the new year.

“This is an important milestone in the future of healthcare technologies, and it is essential that we understand the state of preparedness at CMS,” wrote Energy and Commerce Committee Chairman Fred Upton (R-Mich.), and Rules Committee Chairman Pete Sessions (R-Texas). "Following the most recent delay of ICD-10, we heard from a number of interested parties concerned about falling behind or halting progress. We would like to acknowledge and thank these organizations and individuals for opening up this dialogue and expressing their thoughts and concerns regarding this issue. It is our priority to ensure that we continue to move forward in healthcare technology and do so in a way that addresses the concerns of all those affected and ensure that the system works."

Whatever happens with this Congress, it is unlikely to end the ICD-10 debate. 

Last week the listserv of the Association of Medical Directors of information Systems (AMDIS) featured a lengthy dialogue on the fate of ICD-10. According to William Bria, MD, CMIO at the HCI Group in Jacksonville, Fla., and AMDIS chair, the organization is currently working on a position paper concerning a way forward with ICD-10.

The discussion on the AMDIS listserv also included a proposal for a “compromise solution” by Joseph Schneider, MD, vice president, CMIO, and medical director of clinical informatics for the Baylor Health Care System.

Schneider points out that there are several concerns about continuing with the Oct. 1, 2015 “big bang” approach. For one thing, he said, there is the risk that some payers, small physician practices and small hospitals—particularly those still dealing with the fallout created by issues related to Meaningful Use—simply won’t be prepared to implement ICD-10 next year.

Schneider also questioned whether there has been “thorough end-to-end testing” of ICD-10. “It’s not happening at the level where it needs to happen,” he said. “So I think there hasn't been adequate testing to make sure this will actually work.”

Considering how disastrous the rollout of was in 2013, Schneider said, the “big bang” approach to ICD-10 should be avoided.

Instead, he suggested that ICD-10 should still be implemented next October, but would be optional for a three-year period, which would protect those payers, small hospitals and physician offices who aren’t ready for it, and would also allow organizations that have made huge financial investments in preparing for ICD-10 to start utilizing it. “So you will get to the implementation of ICD-10 at the end of that time without massive disruption.”

At the same time, Schneider said, he would also like to see a conversation started to see whether there is a better way to move forward with coding. That conversation could be started with the formation of a multi-disciplinary panel that could look at different options, like pushing for ICD-11 by 2020 and keeping ICD-10 optional until then; getting physicians and hospitals working in SNOMED and have EMRs capable of translating those codes electronically into ICD-11 by 2020; or making ICD-10 mandatory by 2018.

To go with the “big bang” approach could have serious implications for the delivery of healthcare in certain areas, Schneider believes. For example, Schneider presented a scenario in which a small physicians' practice or critical access hospital with five or six payers has a couple of those payers run into some significant problems with their ICD-10 software.

“Let’s say they thought they were ready, did some testing, but found out they weren’t ready and that they won’t be able to pay you and it’s going to take them six months to work out the bugs,” he said. Losing that revenue stream—even for six months—could seriously impact the ability of some of these healthcare organizations to remain open, or provide services, he said, adding that will be a real public health problem if these are organizations serving rural or underserved areas.

With the phased-in approach, Schneider believes that the majority of healthcare systems would still go forward next October because “they think they are ready, have people trained and will be ready to go.”

“What will happen is that over the next few months folks will really see whether they’re ready or not,” he predicted. But if everything goes right, he added, there should be a relatively small portion of providers who won’t be ready to go—“but they will be important ones because they are the critical access hospitals and rural office practices.”

Ultimately, Schneider said, “I would like us to solve this ourselves. The clinical world should find a way to take care of its own house, and the fact that we are in this position is a real failure across the board,” he added. “We didn’t get together as a clinical healthcare system and figure out the right answer so that we wouldn’t have to go through this situation.”