ICD-10 Delay: What’s Next For Healthcare Organizations?

By Kaveh Safavi, M.D., J.D. for InformationWeek-HealthCare

Healthcare organizations have at least four options for dealing with the delayed implementation of new diagnostic codes.

Many of the complexities of medicine are distilled down to a vocabulary of diagnostic codes, called the International Classification of Diseases (ICD), which are used by doctors, insurers, and hospitals. Today’s ICD-9 codes are now more than four decades old. Although the US was aiming to transition to ICD-10 by Oct. 2014, the recently announced postponement, until at least October 2015, presents a dilemma for many providers that were ready to activate the new system. The question that remains is how best to move forward?

It’s not hard to imagine how the added specificity will drive advancements in managing patient populations, as providers and payers transition from roughly 14,000 codes in ICD-9 to around 69,000 in ICD-10. The lack of detail in ICD-9 has often compromised the accuracy of coding, with the conveyed information subject to differing interpretations. For example, the trimester of a pregnancy is clinically relevant to many patients’ cases, but ICD-9’s coding is not specific enough to convey this information.

The change has been a long time in coming, but readiness levels vary. It isn’t just a question of coding work — organizations’ workflows and processes must also be re-engineered. A database using the language of ICD-10, say, will not work properly with models that still speak ICD-9.

Think of a classic bell curve: While many organizations are at the middle or advanced end of the curve, there are also those that are behind.

Many of the organizations working on ICD-10 have been simultaneously implementing electronic medical record (EMR) systems that take into account the new codes. While ICD-10 wasn’t developed for payment systems, these EMRs lead to reimbursement and revenue cycle systems. The two go together; unless both function effectively, providers risk not getting paid.

Organizations ready for ICD-10 may see this delay as an inconvenience, though, a pragmatic compromise if it nudges the full industry closer to compliance. Providers still completing remediation and testing may intend to stick with their timelines, but will now know there is room for slippage. Any that are significantly behind will definitely see the delay as giving them an extra year to readjust priorities.

All organizations will want to use the delay to trigger a review of their readiness, and the results will in large part determine their response. The extra time also gives a bigger window for remediation and testing, including external testing, as well as giving providers longer to comply with the meaningful use directive (and package vendors to obtain meaningful use certification).

On the other hand, the delay will increase the cost of the ICD-10 program and may cause difficulties with resource allocation, particularly since this is the second postponement in two years. Those organizations that have completed date-sensitive remediation may now face additional work. And there will be a need for additional general equivalence mapping (GEM) between the two standards.

So where does that leave health organizations? The onus is on individual providers and payers to determine a bespoke plan that meets their business needs and timeline. But that plan is likely to fall within one of four possible contingency options:

1. Stay the course: This is likely to be the preferred option of providers and payers that have completed remediation and are now in testing, as this will allow that work to be finalized. Potential disadvantages include the possibility that the readiness of providers and payers is out of step. It’s also possible organizations will require additional funding to support the extension, or even that staffing levels may have to be reduced in the hiatus period preceding the compliance date.

2. Slow down: By stretching the work that still to be done over the course of the extension, there may be less need to increase budgets and resources. However retaining staff over the extended timeline may prove difficult, raising other concerns.

3. Be pragmatic: Some organizations may choose to stick to their original timelines where possible, accomplishing what is feasible and realistic this year while reserving a small budget to complete deferred work next year. This will enable them to focus resources on areas according to current readiness levels.

4. Stop: One option is to stop work completely for now, maintaining the budget until a new compliance date is set. This presents organizations not ready for ICD-10 with potential problems such as having to relocate skilled resources once work begins again — inevitably, the whole program will take time to ramp up. This may be a favored option for organizations that have already completed remediation and external testing.

All four options have pros and cons, which will be more or less significant depending on where the organization currently stands in its preparations. But the delay to ICD-10 is a reality — and organizations must now decide how to respond.

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