Back to the Future on ICD-10?
A year ago, we were all on ICD-10 watch at this time. Odd makers were all taking sides as to what would happen with the deadline of October 1, 2014 to submit on ICD-10 billing codes to Medicare and Medicaid (the largest single payer of medical care in the United States). Insurance companies and hospitals were all rushing to meet the deadline to have Congress intervene and push off a full year. Today the watch is the same, and maybe with the Medicare Sustainable Growth Rate (SGR) issue resolved, (see our blog of The SGR is Dead!) it might happen again.
For those not familiar with the issue – ICD stands for International Classifications for Diseases (ICD) system and as you would expect ICD-9 is version 9. Most of the developed world today using ICD-10; this upgrade requirement will result in an eightfold increase in the number of diagnostic and procedure codes from currently 17,000, to more than 140,000. The new codes capture more detailed data on everything from pregnancy symptoms in different trimesters, to a leg break on the left side versus the right side. Doctors, nurses and coders are undergoing a lot of training to get the new billing process right.
The professionals are still thinking, saying or maybe praying it will not be delayed again, as billions have been spent industry wide. This delay has caused many problems! I can tell you about students who graduated from programs where they only learned ICD-10; this would create a problem if ICD-10 did not go into effect. On their own will, students would have to go back and learn it if they could. How do you go back in time to learn something like that?
The issue now is that most small group and individual doctors are still not ready, and who can blame them? There have been so many changes around technology and how they report things, that not a single thing has been done to make the doctor’s lives easier or a return their time invested worthwhile. To have a gross income adjustment of half of 1% for the next 5 years from Medicare is also kind of insulting however, it’s clearly better than a double digit drop.
The real problem is… as reported in an exclusive survey:
“designed by the editors of Healthcare Informatics, and conducted by QuantiaMD, a Waltham, Mass.-based social network for physicians. QuantiaMD surveyed 181 physicians and found that 62 percent say there should be another delay to ICD-10. Of that 62 percent (114 physicians), more than half (53 percent) are advocating for an indefinite delay to the code-set.”
I can tell you that from personal anecdotal experience with physicians, the numbers in Florida are worse.
Recently H.R. 2247 was introduced in the U.S. House of Representatives that mandates “clarity” for providers. Effectively, this ICD -10 Act would “require the Secretary of Health and Human Services (HHS) to provide for transparent testing to assess the transition under the Medicare fee-for-service claims processing system from the ICD-9 to the ICD-10 standard, and for other purposes.”
This H.R. 2247 bill was introduced on May 12, 2015 by Rep. Diane Black (R-TN-6), and would not actually halt or delay the October 1, 2015 implementation deadline for using ICD-10-CM/PCS, nor would it require the Centers for Medicare and Medicaid Services (CMS) to accept dual coding—claims coded in either ICD-9 or ICD-10. However, the bill would require HHS to conduct “comprehensive, end-to-end testing” to assess whether the Medicare fee-for-service claims processing system based on the ICD-10 standard is fully functioning. HHS would be required to make the end-to-end testing process available to all providers of services and suppliers participating in the Medicare fee-for-service program.
The most important part is that during an 18-month transition period, and any ensuing extensions, no reimbursement claim submitted to Medicare could be denied solely due to the “use of an unspecified or inaccurate subcode,” according to the bill.
The battle lines have been drawn and most think that the large enterprises and non-physician trade associations want it to be over. On the other hand, The American Medical Association has come out in support of another bill – H.R. 2126.
From the AMA website:
H.R. 2126, the “Cutting Costly Codes Act of 2015,” was introduced by Representative Ted Poe (R-TX) on April 30, 2015. This legislation would prohibit the Secretary of HHS from replacing the current International Classification of Diseases, 9th Revision (ICD-9) with the ICD-10 diagnostic code set. In addition, it would require the GAO, in consultation with stakeholders, to conduct a study on ways to mitigate the disruption on health care providers resulting from a replacement of ICD-9 with ICD-10. The current deadline for implementation of ICD-10 is October 1, 2015.
Physicians are overwhelmed with the prospect of the tremendous administrative and financial burdens of transitioning to ICD-10. ICD-10 consists of 68,000 codes — a five-fold increase from the approximately 13,000 diagnosis codes currently in ICD-9. Implementation of ICD-10 will affect physician claims submission and most business processes within a physician’s practice, including verifying patient eligibility, obtaining pre-authorization for services, documentation of the patient’s visit, research activities, public health reporting, and quality reporting. As HIPAA-covered entities, physicians will be responsible for complying with this ICD-10 mandate, and therefore will bear the entire cost of such a transition. Furthermore, physicians face the prospect of significant disruption in claims processing and payment during the transition to ICD-10 and any physician who is unable to transition to ICD-10 by the implementation date simply will not get paid. The AMA strongly supports this legislation and continues to seek repeal of ICD-10.
I am not a gambling man however, I would bet that as we gear up for a new election year, the AMA and the “overwhelmed” physicians have a good chance. I also have a great deal of empathy as they are overwhelmed, and in my opinion, underpaid for their efforts. I would suggest to the Department of Health and Human Services, who administers both Medicare and Medicaid, to allow both, ICD-10 and ICD-9 for the next 3 to 4 years. This transition would avoid what is likely to be a problem.
I hate to be the bearer of more bad news for my physician freinds, but there are those who now say we should just skip ICD-10 and go right to ICD-11 . The World Health Organization is currently working on, and finalizing, a review of ICD-11 for possible adoption in 2017.
– Noel J. Guillama, President
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