October 2010 Implementation Date for ICD-10 is Unworkable
August 10, 2006
Issue: Congress is now working to conference the House (H.R. 4157) and Senate (S. 1418) health information technology (IT) bills. The House bill would require all providers and payers to convert to ICD-10 codes by October 2010. The Senate bill does not include the ICD-10 mandate.
Position: BCBSA – along with a coalition of physicians, labs, and other providers and insurers – urges Congress to provide an ICD-10 compliance date no sooner than October 2012 – 3 years after "5010" adoption. The House deadline of October 2010 is not workable because:
- ICD-10 is a massive and costly undertaking that places huge burdens on physicians/others.
- Providers and payers must first adopt the next generation of HIPAA transactions before converting to ICD-10.
- Medicare would be put at great risk of delayed and improper payments.
Providers and Payers Need until October 2012 to Convert to ICD-10:
ICD-10 is a massive and costly undertaking, placing huge burdens on physicians/others.
The ICD-10 code set has 200,000 codes, almost 10 times the 24,000 codes in the ICD-9 code set. Providers and payers will need to completely redesign their business processes and systems to handle these hundreds of thousands of new codes at an estimated cost of $14 billion (2004 Nolan report). Although other countries have switched to ICD-10, no other country uses a version of the ICD-10 code set that is as complex and granular as the U.S. version.
- Physicians and other providers will have to substantially overhaul their practices. All clinical and administrative staff will need critical education and training and ongoing and costly electronic support systems.
- Pen and paper will no longer suffice to code diagnoses – physicians will need new decision support technologies at the point of service to identify the correct codes. Unless physicians have the support systems in place to perform real-time coding while the patient is in the office, it will not be possible to achieve the benefits from the greater specificity of ICD-10.
- Physicians will not be able to rely on clearinghouses, as they did for HIPAA transaction standards. (Clearinghouses translate claims into HIPAA-compliant formats and forward those claims to payers.) Physicians and their staff will need to assign ICD-10 diagnoses themselves.
Providers and payers must first adopt HIPAA version "5010".
- Before the transition to ICD-10 can begin, industry must move to the next generation of HIPAA transactions (version 5010) because the current version (4010) will not work with ICD-10. Version 5010 is a major re-write of the HIPAA transaction standards, with more than 850 individual changes. There is wide industry consensus, expressed in a letter from the Workgroup on Electronic Data Interchange (WEDI) to HHS, that upgrading to version 5010 "is too significant to be done in conjunction with ICD-10."
An October 2010 date would put Medicare at great risk of delayed and improper payments.
- In the largest contracting change since Medicare's inception, CMS is now transitioning more than 50 fiscal intermediary and carrier contracts to 15 Part A/B Medicare Administrative Contractors over the next 3-4 years. This is a complex task transferring workloads from multiple contractors to a single entity, while at the same time integrating Part A and B claims processing systems and modernizing CMS information and accounting systems. The Government Accountability Office warns that this massive consolidation in itself has the potential to cause major service problems for Medicare.
- Simultaneously switching to ICD-10 by 2010 would further overwhelm Medicare contractors' IT departments, leading to claims backlogs, delayed payments to beneficiaries and providers, and increased opportunities for fraud. After studying the issue, former HHS Inspector General Chief Counsel Thornton concluded that rushing ICD-10 would cause Medicare improper payments to soar.
Therefore, ICD-10 cannot be implemented sooner than 2012.
- Industry should not begin to implement ICD-10 until 2009, after providers and payers have implemented version 5010 and Medicare contracting changes are completed. Then, providers and payers will need 3 years to implement ICD-10.
- A key lesson learned from HIPAA is that provider education and outreach is critical to ensure providers are aware of the changes that must be made and adequate time is given to make those changes.
The Blue Cross and Blue Shield Association is made up of 39 independent, locally operated Blue Cross and Blue Shield companies that collectively provide healthcare coverage for more than 97 million – nearly one-in-three – Americans.
