On Wednesday, January 21st, the Obama Administration put the ICD-10 final rule, along with others that are pending, on hold while further review is conducted. Don’t start cheering yet! This does not mean the rule won’t become official on March 17, 2009, it just means there might be the chance of a delay.
A likely part of the final rule that Obama’s Administration will review are the comments that were received in response to the August 22, 2008, Proposed rule. These comments deal mainly with the decision to adopt the ICD-10 code set in the U.S. in general and the impact of implementing this change. In an attempt to better understand the industry wide perception of this upcoming switch, the comments that were received will be discussed.
According to the final rule, 3,115 public comments were received in response to the proposed rule. The different sectors that submitted comments include, but are not limited to: physician practices, coders, State Medicaid agencies, tribal representatives, and disease-related advocacy groups. The majority of comments received were in support of the proposed switch to ICD-10 but the proposed implementation date received a fair amount of criticism. The main reasons for agreement with this switch included: catching up with the rest of the world which is already using ICD-10; replacing a compromised coding structure due to a lack of space for adding new codes in ICD-9 Volume 3; and easier support for the more detailed information requirements as providers move towards electronic health records.
Comments were received that did not support the change and offered up alternative options for eliminating the short falls of the ICD-9 code set. Alternative solutions included: annually eliminating codes that are no longer relevant; using the rest of the available space in the 00 and 17 overflow chapters; and waiting to adopt the ICD-11 code set. In response to these comments it starts to become clear that the true solution is to move to ICD-10. Currently the ICD-9 code set is updated annually by removing and modifying existing codes. Maintaining ICD-9 is not a dependable long term solution to create more space since there is no guarantee that each year codes will be removed in sections where new codes need to be added. Continuing to use the 00 and 17 overflow chapters is not sustainable since those will also run out of space and it makes it very difficult to find appropriate codes since they are being placed under generic sections and not body system specific ones.
The idea of waiting to adopt ICD-11 actually struck me as having some potential. It seems counterproductive for the US to spend so much time and effort, not to mention money, to convert to a code set that might be outdated by the time we get around to actually using it. After hearing further details related to the ICD-11 code set I came around and realized it is in the best interest of the US to move to ICD-10 first. It appears ICD-11 will not be to a point to even consider rulemaking for implementation until 2020. With the current state of ICD-9 that is too long to wait for a solution. ICD-11 has an alpha-numeric format that is based on ICD-10 which will ultimately make that switch easier to handle, whenever that day comes. There is some hope that we won't be forever behind the times.
One of the biggest points of contention appears to be the original proposed implementation date of October 1, 2011. Most comments that were related to implementation date claim that the original date does not provide enough time for necessary training and implementing new systems with adequate testing. The biggest reason for wanting more time was to accommodate the need to implement the ICD-10 changes in addition to the Version 5010 transactions standards. As a result of industry concern, the implementation date has been extended to October 1, 2013. This should give everyone enough time to work towards version 5010 and ICD-10 without compromising system accuracy due to a shortened testing window.
As we find out more information about the fate of the ICD-10 Final Rule in the Obama Administration we will keep you updated.
Final rule, 74 FR 3328, Jan. 16, 2009; CMS Release, Jan. 21, 2009.