The ICD 10 Extension: For whatever reasons, Congress did the right thing!

Did you hear the one about the CMS administrator who was asked what it would take to delay the 2014 ICD-10 implementation deadline? An act of Congress, he smugly replied, according to unverified reports.

Good thing he didn’t say an act of God.

So, now that CMS has been overruled by Congress, who wins and who loses? Who’s happy and who’s not?

The answers to those questions illustrate the resource disparity that prevails in healthcare and, mirroring the broader economy, threatens to get worse. The disappointed Have-a-lot hospitals are equipped with the resources to meet ICD-10 deadlines and always felt pretty confident of a positive outcome; the Have-not facilities were never all that sure they would make it and are breathing a collective sigh of relief.

First off, it is necessary to recognize that ICD-10 is far superior to ICD-9 for expressing clinical diagnoses and procedures. Yes, some of the codes seem ridiculous … “pecked by chickens,” for example. But people do get pecked by chickens, or plowed into by sea lions, so I believe the intent is positive, as will be the results.

An example: I saw my physician this past week at a Have-a-lot health system in San Francisco and I asked what she thinks of the ICD-10 extension.

“We’re already using (ICD-10) in our EHR and it is much better than ICD-9,” she said. “When I want to code for right flank pain, it’s right there. I don’t have to go with back pain or abdominal pain and fudge flank in. It’s easier and more accurate.”

“If I was still on paper and not our EHR, which I like,” she added, “my superbill would go from 1 page to 10. SNOMED works.”

And there you have it. The Have-a-lots have prepared, invested millions and are now wringing their hands over the delay. And why shouldn’t they? They’ve gone so far as to help their docs understand how comprehensive SNOMED CT terminology helps them be specific and accurate. Now they want to finish the project.

On the flipside, the Have-nots have been given a reprieve from the potential financial catastrophe predicted by the HIMSS/WEDI ICD 10 National Pilot report:

The “perfect storm” will be quickly descending upon the healthcare system … All ICD-10 impacted organizations should act now to allocate as much time as possible for testing and remediation to protect their corporate bottom lines and cash flow to successfully achieve compliance.

The reimbursement hit for foundering Have-nots would put their narrow margins into the red. Their physicians would struggle with trying to code without adequate training and tools, further eroding time with patients. Even the Have-nots with EHRs still lack the resources to fully prepare and train for both MU Stage 2 and ICD-10 this year. The EHR and coding technologies are essential tools but results are based on preparation and change management, i.e., services and time.

In a statement released following the ICD-10 delay, New York-based financial information services company Fitch Ratings described the one-year extension of ICD-10 as a “positive credit development” for not-for-profit hospitals. The statement recognizes the significant investment many hospitals have made, but still warns against potential disruption of the revenue cycle and the disproportionate impact this could have on the Have-nots.

While a majority of providers have made the substantial investment in technology and personnel to be ready for the transition, the readiness of both governmental and commercial payers to adequately process claims and payments in a timely manner has been questioned. In our view, lower rated credits would be more susceptible to this risk as they have less financial resources to absorb a potential delay in reimbursement.

With the ICD-10 delay, we avoid putting a significant portion of our provider organizations out of business; we assure the patients of many safety net organizations that they still have a place to receive care.

But is there a risk that we get into a series of rolling delays and extensions?  The danger is real. The World Health Organization says ”the 11th revision process is underway and the final ICD-11 will be released in 2017.”

ICD-9 was released in 1979. ICD-10 in 1999. While most countries that aren’t the US adopted ICD-10 upon release, we are still extending, which gives rise to some serious questions: When will ICD-11 be mandatory in the US? How long will it take for products and systems to be ready?  How many years on ICD-10 is worth the cost before changing again?

We know that the Have-a-lots are migrating to and using ICD-10 now, and we can feel confident that they will continue moving forward to ICD-11. For the Have-nots, Congress may have to come to the rescue again.