As ICD-10 Deadline Looms, Healthcare Providers Fret

Healthcare providers, payers, the government, and other players in the ICD-10 changeover are not working in a cohesive and coordinated fashion and won't be ready for the transition in eight months, says an MGMA policy expert.

The looming Oct. 1 implementation for ICD-10 has healthcare providers antsy about a potentially rocky transition to the new diagnostic code set in the midst of other fundamental and profound changes to the healthcare sector.

A Medical Group Management Association survey of more than 570 practices representing more than 21,000 physicians finds that less than 10% of them had made significant progress when ranking their overall readiness for Oct. 1, up from 4.7% in June, 2013.

MGMA Senior Policy Advisor Robert Tennant says providers, payers, the government, and other players in the ICD-10 movement are not working in a cohesive and coordinated fashion.

"ICD-10 is like a cascade. Things can't happen until other things happen," Tennant says. "What we are finding through research and discussions with our members and industry [is that] the pieces aren't coming together as quickly as the government had expected them to. That includes software vendors, clearinghouses, [and] health plans. Nobody seems to be out front and leading the pack, and that includes the government."

He notes, for example, that there are only eight months until the implementation date and Medicare has not yet released its payment edits. "They've not yet begun to test with providers and even when they do so in March they are only going to do front-end testing. They aren't going to test the claim from start to finish. This is a recipe for disaster if all of these pieces don't come together," he says.

ICD-10 was supposed to take effect on Oct. 1, 2013 but the Department of Health and Human Services in 2012 rolled back the deadline for a year after providers complained. MGMA has not called for another implementation delay, but Tennant says the likelihood of a smooth transition diminishes by the day.

"Can it get done in time? Let's just say that everything came together in September. That is not enough time," he says. "The industry is a little like the Titanic. It can turn, but very slowly. We are concerned that there won't be enough time for testing. The government experienced that with healthcare.gov."

"If you don't test, you run the risk of problems," Tennant says. "And ICD-10 impacts every part of healthcare on the practice side, the clinical, the administrative, the entire revenue cycle. So, if things don't go smoothly it could dramatically impact cash flow for practices and ultimately that could impact patient care."

Flipping the switch to ICD-10 will come at the same time that providers are grappling with interoperability and other complex issues under Meaningful Use Stage 2 that must be implemented to avoid financial penalties. In addition, no one really knows how the first full year of the Patient Protection and Affordable Care Act will play out for providers as the healthcare sector continues its shift towards population health, value-based payments and accountable care, and other fundamental changes.

Russ Branzell, CEO of the College of Healthcare Information Management Executives, doesn't believe the ICD-10 implementation deadline should roll back again, but he concedes that providers have too much heaped on their plates all at once.

"We need to allow providers and hospitals to really focus on ICD-10," he says, "but we are also concerned that there are too many competing initiatives that are converting around the same time frame—everything from meaningful use, security requirements, ACOs and population health—all of this is converging at the same time and distracting from getting ICD-10 appropriately resource staffed, process improved and implemented."

Instead of rolling back the ICD-10 deadline for a second time, Branzell says the federal government should give providers another six months or longer to implement Meaningful Use Stage 2 before suffering any financial penalties.

"In a medium-sized medical group, if you have too many competing initiatives for caregivers, there is not a lot of focus on anything. And with ICD-10 there so much that still needs to be done, especially on the provider end, training and understanding the documentation requirements and the new systems. If they have to do that while they are trying to figure out Meaningful Use Stage 2, something has to give."

Branzell believes that many providers will opt to delay Meaningful Use Stage 2 and suffer the penalties as they attempt to launch ICD-10.

"We share MGMA's concerns, especially for the provider side of this," he says. "We think most of the hospitals have a good grasp on ICD-10. They don't have all the training and work they are supposed to have had done but generally the hospitals have a good grasp on this. But even on the hospital side we think they need to focus and have the flexibility."

"It doesn't mean that they should delay anything, but they should have some flexibility so if anyone needs to move back Meaningful Use Stage 2 they are not suffering penalties so they can focus on this. If we allow everyone the flexibility they need, maybe six or 12 months, we can get all of these initiatives accomplished in an appropriate sequence and timing."

Why not rollback the ICD-10 deadline and allow providers to focus on Meaningful Use Stage 2?

"For ICD-10, the ship has already sailed," Branzell says. "Most hospitals have already upgraded their systems. Many are already running dual accounting systems to check on this. At this point so many have geared up and there is an expense that has been laid out for most organizations that if they were to delay this date there would be lost effort and they would have to turn around and do it all over again."

He says the previous delay to ICD-10 implementation in 2012 was done so far in advance that providers had yet to spend a lot of money on the project. "Now a lot of organizations have command centers and teams dedicated to this and they have already invested in training resources, all of which is in place for Oct. 1. What do you do with all of that? Shut it all down? That would be very expensive."

Tennant says the federal government needs to prepare some sort of contingency plan or a rollback for ICD-10 if the Oct. 1 deadline proves to be untenable. "They have to do something quickly rather than wait until the ninth hour and announce something in late September. Better to do it now to prepare for the transition," he says.

"They frankly haven't even created an environment where physicians are confident about why the government is moving toward this new code set. There is no evidence to suggest that it improves clinical performance. There is no evidence that there is a return on investment which is staggering when you consider the cost of this for practices. What we have learned in the last few months is that you have to be ready for major transitions. And if you're not, they must be put on hold."