Journal of AHIMA - June 2012

ICD- 10 Delay Impacts

Benefits of a Delay

IF ORGANIZATIONS KEEP advancing their implementation plans, one benefit of a delay is that providers will have a longer time to test ICD- 10 within their systems. Many vendors and health plans have said they will be ready to test ICD- 10 in the third quarter of 2012. Using all of 2013 to test a system will allow the industry to work out more bugs and lead to a smoother transition when the compliance deadline arrives, Rode says.

“That’s a much bigger window than we had originally,”
he says. “Although the original window was certainly long
enough if everybody was moving in the same direction,
which apparently they were not.”
The delay could also be used to align the various federal
initiatives—one current hardship cited by the AMA as a rea-
son for delay—like meaningful use, ACOs, and other pro-
grams involving quality measures and ICD- 10 so it is easier
for all providers to become compliant, Westhafer says.

“As all of these various initiatives came forward separately, you do start to wonder about ‘Did anybody think how to sequence and line them up so they all work together for good?’” she says. “If truly that is done, I do think that could be a positive coming out of this. I worry, however, that there is just too much politics at play.”

in a policy statement. “Accurate healthcare data is required
to support other national healthcare initiatives such as qual-
ity measurement, patient safety, value-based purchasing, and
widespread use of health information technology and interop-
erability.”
While AHIMA prefers no delay of ICD- 10, CEO Lynne Thomas
Gordon, MBA, RHIA, FACHE, said in a press release shortly af-
ter the delay announcement that the association is gratified that
HHS recognized “the hard work and efforts already expended
in the implementation process” in proposing only a one-year
delay.

Thomas Gordon noted that AHIMA’s call for HIPAA-covered
entities to continue their ICD-10-CM/PCS implementation was
justified when looking at the HHS analysis. “The transition to
ICD- 10 is inevitable and remains the future for coding classifi-
cation systems,” she said. “We are sorry to see that our members
and organizations following HHS’ initial calendar may suffer
from the delay, as will our many higher education colleges and
universities that changed their curricula to meet this same re-
quirement date.”
AHIMA offered its help to any provider struggling to imple-
ment ICD- 10. “We are empathetic to the pressures many small
providers and practices have meeting the current requirements,”
Thomas Gordon said. “But a continued delay and uncertainty
in the implementation date is in no one’s best interest. Further
delays in our nation’s efforts to implement electronic health re-
cords and information exchange will only increase costs in the

long run and result in lost benefits from having health information available where and when it is needed.”

Impact on Government

Several government programs and initiatives are planning to use ICD- 10 codes beyond the CMS healthcare reimbursement system. ICD- 10 is being tied to several quality improvement initiatives that will use the more specific code set to better track care. For example, the stage 2 meaningful use program’s proposed rule includes quality measures that require reporting through ICD- 10 codes, Rode says.

AHIMA recently worked with the National Quality Foundation to integrate ICD- 10 into quality measurements, enabling the measures to now track aspects like patient status and severity. A delay of ICD- 10 means programs like meaningful use will need to evaluate when they start requiring ICD- 10 and possibly hold off on aspects of the program. Other initiatives that were designed to reimburse physicians based on quality rather than charges also used ICD- 10 codes and may be altered or delayed.

“Whether it is associated with meaningful use or it is associ-
ated with one of the reporting programs, CMS just won’t have
the detail, and plans that were made to change (to ICD- 10)
will be impacted,” Rode says. “An option they have is holding
the program off, and given that one of the caveats is just all the
other changes associated with the implementation of electronic
records, they may decide that it is easier to just go one more year
under the existing program than to make a change.”
Using the old code set in these programs delays the planned
improvement that ICD- 10 would bring and also jeopardizes
current investment in the code set. The longer the delay, the
more likely the government will have to redo ICD- 10 efforts in
order to bring stalled programs up to speed once again, Rode
says. This equates to wasted money.

Despite a delay, AHIMA has urged HHS to embed ICD- 10 compatibility and use in the stage 2 meaningful use measures and certification standards. This will ensure that anyone who upgrades their health IT systems to meet stage 2 will also be ICD- 10 compatible. ICD- 9 is used in various ways in an electronic health record system. Organizations that want to meet meaningful use and implement an EHR that only supports ICD- 9 codes will face additional expenses when they are eventually forced to use ICD- 10.

Working ICD- 10 into official government EHR certification now will save facilities from having to retrofit those systems to ICD- 10 as the industry nears the revamped implementation deadline, Rode says.

Advocates fear an ICD- 10 delay will take some of the pressure off the government and EHR vendors to utilize ICD- 10 in their programs and systems now.

“The longer we delay, presuming there is not a certification requirement (for ICD- 10), then the more retrofitting that would have to be done by an organization when the compliance date is put in,” Rode says.