Advanced Revenue Cycle Analytics: An Overview

CMS administrator Marilyn Tavenner hinted at a delay in ICD-10 implementation when speaking to an AMA meeting on Tuesday, February 14, 2012. Rather vaguely, Tavenner said CMS would “reexamine the timing” of ICD-10 implementation. Two days later Health and Human Services (HHS) Secretary Kathleen Sebelius removed all doubt when she stated that HHS “announces intent to delay ICD-10 compliance date.” 

Undetermined Delay to ICD-10

Unfortunately, no one in the industry knows how long this delay may last. 

Tom Sullivan, editor of Government Health IT, published an intriguing blog post four days later introducing the idea that there may be a case for leapfrogging ICD-10 and going directly to ICD-11—depending on the length of the ICD-10 delay. Sullivan points out that ICD-9 was essentially completed in the early 1970’s and thus reflected 1960’s theories of health and technologies; likewise ICD-10 was completed in 1990, therefore reflecting 1980’s thinking. 

After the 2012 ICD-10 summit, a poll was taken with over 50 senior healthcare professional participants. Among the findings were:

“Nearly two-thirds of respondents (64 percent) believe a delay will not improve readiness, 76 percent believe a delay will harm other healthcare reform efforts, and 69 percent say a two-year delay would be either ‘potentially catastrophic’ or ‘unrecoverable.’”

Skipping ICD-10 and Adopting ICD-11

If the delay to the ICD-10 changeover is going to take an additional year, should everyone just wait for one big jump to ICD-11? The main benefit would be to allow physicians and healthcare practices to have one big transition rather than two in short succession. One of the biggest arguments against skipping ICD-10 is that ICD-11 is simply not ready yet for “prime time”.

“ICD-10 is the pathway to ICD-11. You have to treat it like you’re building a structure starting with a first floor. You can’t build a fourth one without constructing a second and third.”
–Sue Bowman, Director of Coding Policy and Compliance for the American Health Information Management Association as quoted by ICD10Watch.

According to HIPAA’s Final Rule, published in the Federal Register, “the earliest projected date to begin the rule making for implementation of a U.S. clinical modification of ICD-11 would be the year 2020.”  The CDC will require several years to make the clinical modification required for adoption of ICD-11 in the United States.

Of course, the actual decision will depend on the length of delay of the ICD-10 implementation and the speed of completion of ICD-11.

Delay Implementation, Not Planning

Regardless of what happens providers must act now to prepare for a substantial adjustment in the number of codes included on paper superbills and in electronic charge capture systems. After all, there was a reason for the delay: Many practices were not ready to meet the ICD-10 deadline. Now you have more time before you have to turn your school project in—wouldn’t you rather be done with it (i.e., planning) early and feel relieved while the rest of the industry is sweating?

White Plume Technologies continues on its development pathway to complete all components well in advance of the original ICD-10 target date.