The health care industry is constantly evolving, and hospitals and other health care providers need a clinical coding system that reflects current medical knowledge, technologies, and practices. A modern coding system enables reliable health care data and payment, quality improvement initiatives, and research to improve health care for patients. While there is no doubt that the transition from the 35-year old ICD-9 code set to ICD-10 involves change and some additional resources for health care providers, the public health benefits of the updated code set are compelling and irrefutable. An implementation delay would threaten public health, cause more disruption to the health care system, and impose $1 billion to $6.8 billion in unnecessary costs. Premier urges Congress to reject any legislative attempts to delay—for the fourth time—full implementation of ICD-10 or to put in place an equally problematic dual-coding transition period.
ICD-10 Implementation Delays Have Been Disruptive, Costly, and Not Fully Leveraged by All Providers
Health and Human Services estimates that the most recent delay alone cost $6.8 billion and a further delay in fully implementing ICD-10 could range from $1 billion to $6.6 billion in additional costs.
Many of Premier's 3,400 hospitals, for example, had to quickly reconfigure systems and processes that were prepared to use ICD-10 back to ICD-9. In addition, newly trained ICD-10 coders were unprepared for the use of the outdated code set and needed to be trained for ICD-9 usage while existing coders that were already trained for ICD-10 had to be retrained given the most recent one-year delay.
The third time is not the charm: Rather than taking advantage of the additional time to ramp up preparation, recent survey results suggest that providers eased up on preparing for the transition from ICD-9 to ICD-10 code sets as a result of the most recent delay in implementation. Two-thirds of respondents indicated they slowed down efforts or placed them on hold after Congress included a year-long extension of the ICD-10 deadline in last year's March SGR "patch" package.
There is no evidence that providers who are resistant to any change would use an additional delay to get ready for ICD-10.
Benefits of ICD-10 Put Off for Far Too Long
The functionality of the current ICD-9 code set has been exhausted by efforts to continue to add codes to describe new procedures and diagnoses. The impact of workarounds, such as creating new codes in unrelated sections or chapters, has eroded the hierarchical structure of the ICD-9 procedure code set.
ICD-10-CM/PCS accounts for increased code specificity as well as new diagnoses and procedures not covered by the current ICD-9-CM coding system. The new ICD-10 coding system will increase the number of codes from the approximately 13,600 codes used now in ICD-9 to approximately 69,000 codes. This will do the following:
• better capture clinical data and link a provider's performance to the patient's condition, improving the ability to measure outcomes and ultimately improve the quality of care;
• be foundational in supporting payments that more accurately demonstrate the acuity of the patient, assisting in efforts to identify risk under population health efforts and to place patients in the most appropriate postacute care setting;
• help our health care industry's larger transition to rewarding providers for quality of care, resulting in the development of more robust quality measures; and
• enable the global tracking of public health outbreaks or current and emerging pandemic events—such as Ebola—which will allow providers to respond more effectively.
"Critical benefits that will be gained from the transition to ICD-10 will be more precise diagnostic reporting, an enhanced ability to capture and utilize health data, and more cost-efficiency in health care operations," says Mary R. Grealy, president of Healthcare Leadership Council. "Not only does it make absolutely no sense to further delay ICD-10 implementation and the improvements it will bring, but the concept of 'dual coding' will open the door to unnecessary confusion and complications. 'Dual coding' will only serve as an obstacle to progress, one that has the potential to undermine health care delivery and patient safety."
Dual Coding Approach Is Unworkable, Confusing, and Costly
If providers are allowed to code using either ICD-10 or ICD-9, even during a limited transition period, submitting claims and communication between providers and others in the health care system would be fraught with problems.
CMS has clearly stated that a dual coding approach is not feasible, neither for itself nor for many commercial health plans that would be unable to process claims for ICD-9 and ICD-10 codes submitted for the same dates of service. Dual coding would lead to payment errors, forcing patients to resolve the confusion between their providers and payers.
Having to figure out which "language" is being used each time a test is ordered, medication is prescribed, or a patient is referred would increase the potential of patient harm and compromise the quality of care. Providers in accountable care organizations, for example, would be unable to effectively communicate with each other to analyze costs, outcomes, and patient safety.
Dual coding would require costly reengineering of the entire data infrastructure of the health care industry, including payment, quality assessment, claims adjudication, and other provider systems that are designed to take advantage of the standardization of a single code set.
"Use of multiple code sets for the same date of service would lead to greater confusion and increased payment errors and disruptions, not less," says Lynne Thomas Gordon, MBA, RHIA, CAE, FACHE, FAHIMA, CEO of AHIMA. "For coders who code for multiple providers, confusion, inefficiencies, coding errors, and productivity losses would occur if they were expected to use both ICD-9 and ICD-10 for the same date of service, depending on the provider. And patients would be the ultimate losers, as they would be faced with payment errors and discrepancies and claims denials as a result of the inability to accurately process or link claims across services from multiple providers."
We Are Ready
Hospitals, providers, health plans, coders, vendors, device manufacturers, researchers, and others in the health care industry have spent billions of dollars and resources to put in place the technology and infrastructure for ICD-10 and are overwhelmingly ready for its implementation.
Over three-quarters of America's hospitals and providers, including the majority of Premier health care alliance members, have been ready to successfully implement ICD-10 since last year, according to a recent survey.
CMS' ICD-10 end-to-end testing in February demonstrates that providers are on course for successful implementation of ICD-10 by October 1, 2015. CMS reported an 81% success rate, with the majority of the rejected claims having problems unrelated to ICD-9 or ICD-10.
CMS itself is ready for ICD-10 implementation, according to a Government Accountability Office report.