Ready, Set, Wait: The Chances of Another ICD-10 Delay

When Congress moved this spring to delay ICD-10 implementation by at least one full year, we were deeply disappointed because it seemed likely to stall the momentum of providers diligently preparing for the transition. The delay also seemed likely to have a negative impact on those providers’ bottom lines – effectively punishing them for having the foresight to prepare for the transition. The most recent data available appears to support that contention. According to the latest survey by the Workgroup for Electronic Data Interchange (WEDI), some key measures of progress give cause for concern.

“It appears the delay has negatively impacted provider progress, causing two-thirds of provider respondents to slow down efforts or place them on hold,” says WEDI chairman Jim Daley in a letter to U.S. Department of Health and Human Services Secretary Sylvia Mathews Burwell that shares the survey’s results. “While the delay provides more time for the transition to ICD-10, many organizations are not taking full advantage of this additional time.”

ICD-10 Prophet of DoomDespite an extra year to prepare, the WEDI survey noted that some stakeholders are delaying key tasks until 2015 – including basic impact assessments, external testing, and releasing ICD-10 compliant documentation and billing products.
The WEDI survey included 324 providers, 103 health plans and 87 vendors. Some of the news was good, including progress in vendor product development, health plan impact assessments and health plan testing. But the survey cited slow progress in other areas. For example:

  • 25 percent of vendors said that their ICD-10 compliant products would not be available until 2015 or responded “unknown.”
  • Only 35 percent of providers had begun external testing, even though 60 percent had expected to begin by the middle of 2014, according to WEDI’s 2013 survey.
  • Only half of the providers said they had finished their impact assessment, which is essentially the same number as in the October 2013 survey.

Another survey by SearchHealthIT and the College of Healthcare Information Management Executives (CHIME) found that only 11 percent of healthcare organizations surveyed were ready for ICD-10. This survey of 326 healthcare organizations reported that 59 percent of respondents have not begun testing ICD-10 adoption. Of that 59 percent, three fourths said they have not completed software upgrades to support ICD-10.

Caution and Skepticism
For some hospital CIOs, the October 2015 deadline prompts caution and skepticism. Meeting the ICD-10 standard requires resources and staff time that are already tied up meeting other government mandates, such as Meaningful Use.

Advocates for ICD-10 adoption gathered on Capitol Hill in September to brief Congressional staff on the switch, arguing that ICD-10 adoption is a positive for the U.S. healthcare system and that further delay would cost hundreds of millions of dollars. However, some proponents of ICD-10 fear that further delays could result from pressure on Congress by the American Medical Association (AMA) and other groups who want more time to implement ICD-10. Indeed, the AMA continues to have concerns about ICD-10.

“The AMA has long considered ICD-10 to be a massive unfunded mandate that comes at a time when physicians are trying to meet several other federal technology requirements, and risk penalties if they fail to do so,” AMA President-elect Steven Stack said in an email statement toFierceHealthIT. “The transition to ICD-10 might also have unintended consequences on quality measurement data, which could lead to CMS being unable to accurately calculate results, and potentially pose unnecessary penalties to physicians.”

Physician readiness is a key concern of Healthcare Financial Management Association (HFMA), which represents some 40,000 healthcare industry finance professionals. In a survey of executive and revenue cycle leaders, HFMA found that 72 percent of health finance professionals surveyed identified physician readiness as the biggest challenge facing ICD-10 adoption.

The case for keeping the deadline
2015 TargetThe new ICD-10 deadline does have momentum behind it, with CMS initiating plans for testing and industry experts contending that ICD-10 adoption makes sense, now. Sue Bowman, Senior Director, Coding Policy and Compliance for AHIMA, emphasizes that keeping the deadline is critical to improving the results of the U.S. healthcare system. In testimony given earlier this year to the Standards Subcommittee of the National Committee on Vital and Health Statistics, she stated:

“ICD-10 is the next generation coding system that will modernize and expand the capacity of public and private payers to keep pace with changes in medical practice and healthcare delivery by providing higher quality information for measuring service quality, outcomes, safety, and efficiency. By allowing for greater coding accuracy and specificity, ICD-10 is key to collecting the information needed to implement healthcare delivery innovations such as patient-centered medical homes and value-based purchasing. ICD-10 will enable better patient care through better understanding of the value of new procedures, improved disease management, and an improved ability to study and understand patient outcomes, yielding benefits to patients far beyond cost savings.”

Bowman also warned of the growing costs of delay. The most recent delay in ICD-10 may be raising implementation costs for participating organizations by up to 30 percent, testified Bowman. She also warned that failure to replace the outmoded ICD-10 had its own set of costs like inaccurate conclusions from faulty data, continued reliance on inefficient manual process, and additional coding errors.

WEDI chairman Daley concluded his letter to HHS Secretary Burwell by calling for continuing industry readiness assessments, industry outreach by HHS and identification of best approaches for the ICD-10 adoption. He also included a stark warning: “Unless all industry segments make a dedicated effort to continue to move forward with their implementation efforts, there will be significant disruption of Oct. 1, 2015.”

We share Chairman Daley’s concerns about the impact of another delay. To help providers plan and prepare for the eventual transition, we have fully enabled our structured reporting and coding solution for the ICD-10 code set, including menu-driven documentation specificity and ICD-9/ICD-10 dual coding functionality in ProVation MD.


Learn more about the steps you should be taking to prepare by downloading our white paper, ICD-10: The Gift of Time.