In less than 90 days, essentially all health care providers will be faced with the unfunded mandate of transitioning to what is called ICD-10 (International Statistical Classification of Diseases and Related Health Problems).
This is the latest and exponentially more complex version of the International Classification of Disease coding system.
There is abundant evidence to suggest that the transition comes with a significant financial and administrative burden that will disproportionately impact smaller medical practices as well as hospital emergency departments.
The recent announcement that the Centers for Medicare and Medicaid Services (CMS) will ease regulations and will not penalize providers for coding errors is, in one sense a welcome gesture.
It shows that the administration recognizes that, for a number of providers, the transition is not likely to be smooth.
The announcement states that CMS will not deny billing claims if the claims are at least partially correct.
CMS will also partner with the American Medical Association to help practices prepare for the transition.
However, a number of practices do not yet even have the necessary IT infrastructure in place. These additional efforts, although well intentioned, are unlikely to help those practices.
If practices are not ready, they don’t just face a 1.5 percent fee cut, they simply won’t get paid.
Even if CMS can mitigate some of the burden of this unfunded mandate, the question that still remains is: Why are physicians and by proxy their patients, being asked to bear this burden?
ICD-10 will not improve patient care.
In fact, the ICD codes have nothing to do with patient care; they are part of the billing process.
In more than 25 years of practicing surgery I have never consulted the ICD codes to help me decide what was wrong with a patient or aid me in treating a patient.
That will not change with ICD-10.
ICD-10 will not allow for early detection of epidemics beyond the precautions and guidelines already established by the Center for Disease Control and the National Institute of Health.
If we have to rely on the billing process to sound the alert the next time an Ebola patient interacts with the health care system, we will be in serious trouble.
Granted, ICD-10 will allow for greater specificity in the submission of billing claims.
But unless fixing a fracture of the right wrist, for example, will be reimbursed differently than fixing a fracture of the left wrist, ICD-10 seems disproportionately complex.
Even in terms of research, there are better options than ICD-10.
When a coder goes through a patient’s medical record and attempts to translate what was done into billing codes, they have one goal in mind, maximizing reimbursement, not producing research data.
Claims data have never been good sources for clinical research.
Support of the ongoing efforts to develop good clinical patient registries is a much better approach to the production of data that will lead to better quality, more efficient care.
It appears that the transition to ICD-10 will be imposed as scheduled on October 1 of this year, perpetuating the bad policy decision of conflating the disparate goals of research and medical billing.
The recent gesture from CMS to provide for a one year grace period is welcome only in so far as it acknowledges that “flipping the switch” to ICD-10 on Oct. 1 is likely to be disastrous.
H.R. 3018, the Coding Flexibility in Healthcare Act of 2015, recently introduced by Reps. Marsha Blackburn, R-Tenn., and Tom Price, R-N.C., would allow providers to use either ICD-9 or ICD-10 for six months.
Although far from ideal, this would at least offer some relief for the many providers who are not ready to switch.
At the very least, CMS should add the provision in H.R. 2652—Protecting Patients and Physicians Against Coding Act of 2015, introduced by Rep. Gary Palmer, R-Ala., and Rep. Diane Black , R-Tenn., that calls for a study of the real-time impact of the transition on medical practices.
This information should help to finally persuade Congress to pursue a better solution—one that will ultimately delink research from the medical billing process.
If not, we will get to do this all again in the near future with ICD-11.