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Shortly after the National Committee on Vital and Health Statistics (NCVHS) recommended that the United States adopt ICD-10, the Medical Group Management Association (MGMA) assembled a session on the code scheme for its annual conference. The last-minute addition was so late, in fact, that the MGMA did not have time to include it on the printed agenda, and the only available time slot was 7 a.m.
Yet the room was overflowing with attendees.
“You couldn’t get in. The line was out the door,” said Robert Tennant, senior policy advisor for the MGMA. “They were terrified.”
That day, nearly a decade before the dreaded compliance deadline, marked the beginning of what would become ICD-10’s reign of fear. And today, with two years remaining before the Oct. 1, 2013 compliance date, the mandate stands to incite more consternation than in all previous years combined.
“Even the mere mention of ICD-10 runs shivers up peoples’ spines,” said Bill Bernstein, chairman of the healthcare division at law firm Manatt, Phelps & Phillips, which works with states and providers on health IT and related public policy issues.
Whether most hospitals will even meet the mandate on time is “a hard question to answer,” said George Arges, senior director of the health data management group at the American Hospital Association (AHA). “One of our concerns right now is the fact that there are so many other overlapping IT initiatives that are also on the docket.”
More Than Fear Itself
Exactly what health IT professionals are afraid of constitutes a scroll of considerable length. But almost everyone asked seems to scare up the words “time,” “resources” and “money” without much thought.
The Department of Veterans Affairs, in a 2010 presentation, outlined the anticipated local impact of the ICD-10 mandate. The short list grows increasingly intense: quality and performance indicators, staff time for modifications, staff time for training, decreased productivity of coders and providers, potential for staff turnover and potential loss of revenue.
Cash flow disruption threatens chaos. Simply put, health entities that fail to comply by Oct. 1, 2013 will find their claims rejected straightaway.
“There is a significant risk that for the first three to six months of the transitions, there will be a real learning curve for providers to code correctly and for health plans to interpret the codes and process them correctly,” said Stanley Nachimson, co-chair of WEDI’s Timeline Initiative, a former senior technical advisor at the Center for Medicare & Medicaid Services and principal at Nachimson Advisors. “There is unpredictability in the revenue flow as the new codes are used to make payment decisions.”
Many of the same payers that will reject ICD-9 claims, meanwhile, may not fully comply with ICD-10 themselves – at least not on compliance day. Rather, they may crosswalk ICD-10 claims into ICD-9, process them internally, then spit ICD-10 back out to providers.
"I know that there's been some talk about people trying to use the general equivalence mappings, but those tools are to help build whatever system changes they need to make in peparation for exclusively using ICD-10," AHA's Arges said. “The idea that you can somehow crosswalk from ICD-10 back to ICD-9 or vice versa, I think, is the wrong message. That would be a problem.”
Tennant added that ICD-10 is not just a conundrum for his physician practice member base. “This is a major issue for payers. I don’t think they know how to get there,” he said. “Our members are just hoping it goes away.”
ICD-10, however, will not so easily be extinguished.
Strength In Numbers
Large health systems such as Kaiser Permanente and the Mayo Clinic will be able to manage ICD-10 compliance by the deadline, according to several experts. Smaller outfits, however, lack the resources, personnel, knowledge and money that the behemoths enjoy.