Late last week the American Medical Association sent a letter to House Speaker John Boehner, asking Congress to halt implementation of the ICD-10 code sets and give the industry time to find a more suitable alternative to the current antiquated ICD-9 codes. The move follows a November 2011 vote by AMA delegates to actively work to end the implementation efforts currently underway. According to the letter, the implementation creates “significant burdens on the practice of medicine with no direct benefit to individual patient care”. The AMA also claims that the ICD-10 effort is competing with other transitions associated with quality and health IT reporting programs.
Background
The Health Insurance Portability and Accountability Act (HIPAA) of 1996 required the establishment of national standards for electronic healthcare transactions and the adoption of national code sets used by providers, payers, and clearinghouses on electronic transactions. The International Classification of Diseases (ICD) is the HIPAA-mandated code set used for reporting diagnoses. The current version – ICD-9 – is over thirty years old and can no longer accommodate expanded use. In 2008, the Centers for Medicare and Medicaid Services released regulations to update HIPAA, including the transition to ICD-10. The compliance date for ICD-10 is October 1, 2013.
AMA’s Argument
During a semi-annual policy-making meeting, the AMA in November voted to fight the implementation of ICD-10, saying that the healthcare industry is overburdened by federal requirements as part of health reform law, health IT incentive programs, and other Medicare and Medicaid (Medi-Cal in California) quality initiatives.
“At a time when we are working to get the best possible value for our healthcare dollar, this massive and expensive undertaking will add administrative expenses and create unnecessary workflow disruptions,” said AMA President Peter W. Carmel, M.D. The opposition shocked most of the industry and the AMA came under fire for causing disruption to a transition that much of the industry is slowly starting to embrace as necessary and overdue. In addition, early responses by the AMA to the ICD-10 transition were cautiously optimistic about the “transformative power” ICD-10 promises to provide for health care.
Industry Response
Reaction to the AMA letter is mixed and it is unclear if Congress will take action to halt the transition. In response to the AMA, the American Health Information Management Association (AHIMA) advised health care providers to continue working towards the implementation, stating they risk missing the implementation date if they wait to see how Congress will act. “Stopping implementation would result in a significant financial loss to healthcare providers, health plans, clearinghouses, technology vendors, and the federal government, all who have invested in the transition and have been preparing for the last three years,” said Dan Rode, AHIMA vice president for advocacy and policy.
The switch to ICD-10 has already been pushed back once – the proposed rule called for an October 1, 2011 implementation, but CMS pushed it back to the current date after overwhelming concern over the aggressive timeline. And despite an announcement by CMS last fall that they would delay enforcement activities following the January 1, 2012 implementation of upgraded HIPAA standards, CMS has consistently held to the 2013 compliance date.
Additionally, the President is committed to modernizing healthcare and ICD-10 is at the core of much of the health IT work already underway. The Health Information Technology for Economic and Clinical Health (HITECH) Act – part of the American Recovery and Reinvestment Act of 2009 - mandates the adoption and meaningful use of certified electronic health records and the Affordable Care Act includes provisions for healthcare entities to certify HIPAA compliance by 2016. The adoption of ICD-10 modernizes diagnostic reporting, provides a standard, updated language of medicine, and allows for the interoperability of health information technology, including health information exchanges.
What’s Next
At this point, no response has been given by CMS or Congress, so the industry continues to wait for more information. The AMA called on the industry to work to find a more “suitable replacement” to ICD-10, but did not offer any alternatives. The AMA currently publishes the Current Procedural Terminology (CPT), the official code set for physician services and procedures. Response to the proposed rule for the implementation of ICD-10 included alternatives, such as expanding ICD-9 or waiting for ICD-11, which is expected to be released in 2015. CMS stated that none of the alternatives suggested adequately address the shortcomings of ICD-9 and that “commenters overwhelmingly supported our proposal to adopt” ICD-10.
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