ICD-10: Staggered implementation could alleviate discord

As the contentious debate surrounding an ICD-10 delay rages on, the Department of Health and Human Services (HHS) fueled the fire on April 9 when it indicated its intention to push the deadline back one year to Oct 1., 2014.

HHS officials partially explained the decision by saying in a written statement, “Provider groups have expressed strong concern about their ability to meet the Oct. 1, 2013, compliance date and the serious claims payment issues that might then ensue.”

To help make its point, HHS cited a CMS survey that found one quarter of providers do not believe they will be ready by the current deadline. It also cited the WEDI survey, which found that nearly 50 percent of respondents do not yet know when their impact assessment will be complete.

In its proposal, HHS stated, “a one-year delay of the ICD-10 compliance date would add 10 to 30 percent to the total cost that these entities have already spent or budgeted for the transition.”

While many providers are struggling to get a handle on ICD-10, others have made great strides in the implementation process and will be hurt financially by the delay.

Is it reasonable to expect those organizations that have made ICD-10 a strategic initiative and have spent upwards of millions of dollars so far preparing for the transition to suffer a severe financial and operational setback because of those who have not?

As I speak to financial and IT executives around the country, I hear one sentiment repeated often: They’ve put a lot of time and money into ICD-10 already and don’t want to lose momentum.

Todd Craghead, vice president of revenue cycle at Intermountain Healthcare based in Salt Lake City, reports that the health system has invested considerable resources in preparing for ICD-10 and the leadership team would rather continue pushing forward than delay for a year.

“We’ve been very active in developing the strategy for migration to ICD-10. It’s governed under the revenue cycle right now. We have around 20 teams that have been active for over a year now,” he said. “The initial reaction by many was a bit of disappointment in that we’ve gotten down the road so far to position ourselves to make the change, and we’ve expended a lot of effort that translates into dollars.”

Barbara Garner, HIM director at Preston Memorial Hospital in Kingwood, W.V., says her organization would also prefer to stay on track with their ICD-10 plans.

“We have been preparing for ICD-10 for quite some time,” she said. “To delay ICD-10 will not make anyone more prepared; the unreadiness will only linger …At some point we just have to work through the complexity of it all. Healthcare is a complex, adaptive system, and we just have to realize that complexity exists and move forward.”

Scott Smith, CFO at Adams County Regional Medical Center, a critical access hospital in southern Ohio, also wants to move ahead with ICD-10. “I would prefer to stay the course and get it done,” he said, noting that from an international perspective, the U.S. is behind the curve and should push ahead.

On March 1, the Medical Group Management Association (MGMA) sent HHS seven recommendations for making the ICD-10 transition easier, including a request for staggered implementation dates.

Perhaps they are onto something.

If some organizations will be ready, while others need more time to prepare, staggering implementation could be a viable solution.

Smith thinks so.

“Why not take a stratified approach to start with urban and academic institutions first? Stagger it in so every facility is not trying to launch it at the same time,” he said.

Given that this is an unfunded federal mandate, why can't CMS accept both I-9 and I-10 codes for a year to make things easier on those providers for whom ICD-10 is a financial hardship, while simultaneously allowing those who will be ready to proceed?

Staggering ICD-10 would also spread out the demand for technology, staff training resources and the stress that will inevitably by placed on the payer side of the reimbursement process.

The ICD-10 conversation is far from over. Write to me at rene.letourneau@medtechmedia.com and share your opinion.