Why we can't skip ICD-10 and go straight to ICD-11

Since the recent announcement by CMS that ICD-10 implementation will be delayed for certain healthcare entities, some industry pundits have argued, “Let’s just skip ICD-10 and go straight to ICD-11.”

Skipping ICD-10 assumes that we haven’t started implementing ICD-10. Well, the U.S. did start—19 years ago.

What have we been doing for the last 19 years?

Federal agencies kicked off ICD-10 implementation in 1993 by preparing to develop a clinical modification of ICD-10 (a U.S. version), then getting a grant and assigning a contractor to develop a clinical modification. Ditto for a procedure coding system.

There were extensive comment periods for both systems, testing of both systems, more comment periods, preliminary crosswalks, adoption of the WHO version of ICD-10 for mortality reporting in 1999, pilot studies, cost analysis studies, coding guidelines and references published, letters urging the adoption of ICD-10 as a HIPAA standard, hearings, and public domain mappings.

There were programs launched to train ICD-10 trainers and a CMS pilot project to convert MS-DRGs, more letters and ICD-10 industry conferences.

Then came the proposed rule, final rule, adoption of HIPAA 5010 in part to accommodate ICD-10 codes, then extensive government outreach programs, and ICD-10 MS-DRG grouper pilot software released for testing, followed by many, many payment, code edit, and care management systems converted to ICD-10.

The quality measures were converted; there was 5010 preparation, more outreach and education, and modifications to both ICD-10 code sets via public process every year since 2003.

And, of course, don’t forget advocacy or resistance from one or another sector of the industry at and between every step taken above and still going on.

Changing from ICD-9 to ICD-10 is not something that just happens on a certain date. To drag this lumbering, squabbling bunch of groups that form the U.S. healthcare system to undertake a change of this magnitude takes time. We can’t skip ICD-10 because we have already spent 19 years getting this close to implementing ICD-10. (2013 would have made it an even 20, a milestone for an effort that began the year the World Wide Web was born!)

It has taken us 19 years to get this far. Unless we willfully ignore our own human nature, we should expect the same slow-mo street fight to implement ICD-11, lasting roughly two decades. This letter (PDF) from the National Committee on Vital and Health Statistics contains an excellent 20-year history of ICD-10 in this country.

We could have skipped ICD-10 in 1993—it’s a bit late now.

Let’s go ahead and implement ICD-10 in 2013 or 2014, and decide now to implement ICD-11 in 2024. Maybe if the healthcare industry sets the timeline up front, we could cut the implementation timeline in half. Planning now for ICD-11 would have the added benefit of establishing a new expectation in the industry—that regular upgrades to any system that facilitates the exchange of data is normal and expected. Postponement as a strategy for doing nothing will not fly any more.

Rhonda Butler is a senior clinical research analyst for 3M Health Information Systems.