October 1, 2015 looks like it may be the final ICD-10 implementation date after members of Congress and representatives from the healthcare industry voiced their support for the new code set during a hearing of the House of Representatives’ Energy and Commerce Committee’s Subcommittee on Health. Despite lingering opposition from some stakeholders worried that small practices will fold under the financial burden of adopting the new codes, the majority opinion has turned in favor of refusing any more delays.
“The last minute delays do nothing to relieve the pressure for the small practice that struggles under this administrative burden,” said Dr. Michael C. Burgess (R-TX), an obstetrician and gynecologist. “It does put the health systems and insurers in a difficult position as well. In fact, it punishes those who have done exactly what Congress has requested.”
“Each delay has been costly to the healthcare system,” added Rep. Gene Green (D-TX). “The ICD-10 transition is an important part of bringing our healthcare system into the 21st century.”
The panelists testifying during the hearing included representatives from medical groups, vendors, payers, and AHIMA, the majority of whom also expressed enthusiasm for keeping the ICD-10 implementation date as it is.
“It is critically important for the health care system to move forward with this new system under the current timetable,” said Carmella Bocchino, Executive Vice President at America’s Health Insurance Plans (AHIP) during her testimony. “Doing so will establish a strong foundation for allowing health plans and health care providers to identify and report conditions and medical treatments in more specific ways, ultimately leading to more effective measurements of quality and health outcomes.”
Bocchino noted that the nation’s major private payers have poured significant time and resources into preparing themselves and the industry for the switch. Aetna, Cigna, and Humana have conducted extensive ICD-10 testing over the past two years, she said, while many of the Blue Cross Blue Shield organizations have provided educational resources and readiness checks for providers throughout the preparation period.
“We need it. We’re ready,” stated Richard F. Averill, MS, Director of Public Policy for 3M Health Information Systems. “Congress rightly wants to move the health care system to focus more on value over volume. I’m here to tell you – you can’t do it with ICD-9. You need ICD-10. It is simply time to have our diagnosis and procedure coding systems reflect modern medicine. ICD-10 is a long overdue replacement for the outdated ICD-9-CM system for reporting diagnosis and procedure information. If we are to rate hospitals and physicians based on their outcomes, we need ICD-10. If we are to better assess what procedures, technologies, or approaches best aid improving patient care, we need ICD-10.”
The hearing comes on the heels of a Government Accountability Office report affirming that CMS has properly prepared its Medicaid systems to handle ICD-10 claims. However, significant skepticism remains about the ability of CMS to handle such a massive undertaking in light of its history with major IT projects.
“All roads eventually lead to CMS,” said Dr. Burgess. “And if you will pardon me, that does appear to be a weak link in the chain. From Healthcare.gov to the Sunshine Act reporting website…when CMS flips the switch, something breaks. Any time they flip a switch that involves the processing of data, their systems fail.”
“So it begs the question: is flipping a switch on October 1 the right move?” Burgess asked. “And if it is, what is the contingency plan for any problems that may develop? Today I am anxious to discuss not just the implementation plan, but I’d also like to talk about the contingencies if everything doesn’t go exactly as planned.”
Contingency planning has largely been left up to individual providers, which are encouraged to take steps such as keeping cash on hand to mitigate the impact of delayed or denied claims. CMS itself has said little on the matter, and is currently focused on conducting end-to-end testing with a select group of sample providers throughout the spring. Recent research has suggested that the financial impact for healthcare organizations may be less than predicted, allowing some breathing room for revenue cycles after go-live.
Overall, the hearing acknowledged that ICD-10 is a necessity for the healthcare industry as it transitions to value-based care and team-based population health management, both of which rely heavily on the improved specificity and more granular data of ICD-10.
“It’s been on the agenda for a long time,” said Rep. Chris Collins (R-NY). “This isn’t something that should be new to anyone. I certainly have a lot of physician friends and I understand there is a cost to implementing anything new. I’m also a data guy, and I know that with data, while it may not be a positive for that patient today, at some point in time being able to deep dive into data is important. Especially with healthcare costs going up in this country as they are, someone will be able to use that data. I would see data collection as a very major part of why we’re doing this.”
Barring the appearance of another behind-the-scenes shocker like the surprise delay in 2014, it appears that ICD-10 implementation is building enough momentum to barrel through continued objections from the American Medical Association and other groups that remain worried about the costs and impacts of the codes. If the October 1, 2015 deadline sticks this time, providers that may have been banking on an additional extension will need to squeeze a number of preparation activities into a quickly shrinking window of just under eight months.