ICD-10: Time's Up; No More Excuses

As worrisome as the final deadlines for use of ICD-10 codes are, it's time to devote significant resources to getting ready for them.

Belittled in some quarters as a make-work, vendor-enriching government regulation, ICD-10 actually gets right to the heart of improving the quality of care.

Don't take my word for it, even if you read my recent story in HealthLeaders magazine. Listen to Sharon Korzdorfer, director of information management at St. Luke's Hospital of Kansas City.

St. Luke's is a not-for-profit, acute-care, tertiary academic teaching institution with more than 600 beds. It is one hospital out of an 11-hospital health system. Eight of the facilities run McKesson EMRs, and the three critical-access hospitals use CPSI, a platform designed specifically for critical access hospitals, with a completely different billing process to McKesson's.

It is the all-too-common bifurcations like this within healthcare IT that make the rich coding provided by ICD-10 so important, not just for satisfying the demands of payers who want ever more billing detail, but to exchange anatomically precise clinical data between different types of hospitals in the same system.

Korzdorfer plans to deploy ICD-10 in both systems at the same time.  The work  starts with an extensive evaluation of the skill levels of staff in areas of pharmacology, physiology, anatomy, and basic terminology. The skill set ranges from coders with one or two years' experience to some who have coded for more than 30 years, she says.

The education component seems like the biggest piece of ICD-10 to me. Hospitals might have some staff who are familiar with the cardiovascular system, but need further help mastering the integumentary system. Korzdorfer says it will take this whole year to get staff the kind of supplemental education needed to prepare for ICD-10.

Like so many others I've spoken with, Korzdorfer says preparation is proceeding as if the original 2013 go-live with ICD-10 were still the case, rather than the 2014 date recently formalized by CMS. But that sound you hear is the feet still being dragged at too many provider institutions.

It's time to stop the foot dragging.

Now, the question is, how.

A simple, clean cutover from earlier coding systems to ICD-10 may not be possible.

"I don't think there's a perfect solution out there, but I think that payers being ready first may make the most sense," says Janice Jacobs, director of regulatory affairs at IMA Consulting, a national independent healthcare management consulting firm working with more than 700 hospitals and health systems throughout the U.S.

And yet, CMS was mute on this suggestion, which was promoted by the Medical Group Management Association among others. So the payers and the health plans get just as long as the providers to get their ICD-10 coding systems up and running. (Aetna, for one, has pledged to be fully ready to process ICD-10 claims by October 1, 2014.)

Jacobs is the experienced voice of reason in a corner of information technology fraught with claims and counterclaims. She is vehemently dismissive of vendors who claim to have ways to generate ICD-10 codes automatically from other coding systems. For instance, I asked her about a suggestion from the American College of Physicians that SNOMED could generate automatic ICD-10 codes from SNOMED-CP terms.

"SNOMED has about 300,000 codes, so even with ICD-10 expanding [by] 168,000 codes, you're still looking at almost double the codes SNOMED would have over ICD-10," Jacobs says. "So how are you going to accurately crosswalk 300,000 codes into 168,000 codes accurately and automatically? That's where I see the problem there. They are two different systems. They serve two different purposes, and there's double codes in SNOMED, so that's what I see as the issue with anything automated."

Another problem, according to Jacobs: Neither SNOMED nor ICD-10 group codes into a Medical Severity Diagnosis Related Group, or MS-DRG. "You'll still need coding personnel that will take the codes, even if they are somehow mapped accurately, and group them into the appropriate MS-DRG codes for reimbursement. So you're kind of looking at a clinical terminology system, a clinical tracking system, versus what you need to get a bill out the door."

One thing that bears additional scrutiny is the possibly disingenuous proposal earlier this year by the American Medical Association to study ICD-10's successor, ICD-11, with the thought of going directly to ICD-11.

"ICD-11 is in the beta phase right now," Jacobs says. "So we really don't know what it is going to look like when it is finally released in 2015. To say that we'll just forego ICD-10 and go to ICD-11 when we don't even know what the final product is going to look like is really frivolous, I think."

According to another consultant I spoke with who prefers to remain unnamed, the AMA has a hidden agenda when it comes to slowing down adoption of ICD-10.

This consultant says the AMA derives significant revenue from providing codes for a somewhat competitive diagnosis system known as Current Procedural Technology, or CPT.

"The AMA licenses CPT to the federal government and agrees to use it exclusively for characterizing physician work," the consultant says. "That's why in the ICD-10 uptake, doctors didn't have to characterize their work with ICD-10 PCS procedure codes. They only had to do diagnosis codes. They were going to continue to use CPT."

Each year, companies pay the AMA license fees for the current version of CPT to embed in the practice management software piece of electronic health records, the consultant says. "CPT owned by the AMA is the AMA's major source of income, because the AMA updates CPT every year," says the consultant.

AMA critics on this CPT issue have been pushed to the margins, and my raising this concern may place me on the margins as well. But it does provide one plausible theory of why the AMA wants to continue to throw a spanner in the ICD-10 works, ostensibly in favor of ICD-11.

And Janice Jacobs' words of concern about the infeasibility of crosswalk technology from any coding system to any other coding system still echo. For sanity's sake, our industry's implementation of the government's ICD-10 mandate needs to hurtle forward, and now.

Shameless plug: If you're ready to roll up your sleeves and get started, or even if you're already under way, a perfect place to start or continue would be my upcoming HealthLeaders Webcast, "Reboot for ICD-10: Lessons from UnitedHealth Group & North Shore-LIJ," scheduled for Monday, October 22 from 1:00 to 2:30 p.m. Eastern time.