Health Affairs: With ICD-10 delayed, policymakers should look to ICD-11
Policymakers should begin planning now for ways to make the coming transition to ICD-11 as tolerable as possible for the healthcare and payment community, according to an article in the March edition of Health Affairs.
Christopher G. Chute, MD, professor of biomedical informatics at Mayo Clinic in Rochester, Minn., and colleagues, wrote on why delaying ICD-10 is important and touched on ICD-11. While the new compliance date has yet to be set, the federal government did delay the Oct. 1, 2013, compliance date for ICD-10.
“We argue, as have many others, that the requirements to meet these specifications—which now includes the requirement to use the Systematized Nomenclature of Medicine–Clinical Terms, or SNOMED CT, for clinical problem lists—constitutes a vast demand on payors’ and providers’ IT resources,” the authors wrote. “Simultaneously requiring the full adoption of ICD-10-CM imposes an unsustainable burden on many.”
Regulatory mandates abound for payors and providers down the line, according to the authors. “New transaction standards for HIPAA that are required by the American Recovery and Reinvestment Act and the Patient Protection and Affordable Care Act (PPACA) impose major changes to most systems that use ICD classifications for payments.” For example, evidence will be specified to support the medical necessity of insurance claims in a new electronic claim attachment standard. The new regulations also will introduce different operating rules for eligibility, claim status and other claims-related transactions, adding to the existing implementation burden.
The impact of other sections of PPACA will impose similar burdens on payors and providers, according to the authors. Health plans soon will be required to endure a certification process related to HIPAA standards and operations. The recent regulations under the PPACA that require plans to pay out in medical claims 85 percent of the premium dollars they collect allow for ICD-10 conversion-related costs to be accounted for as quality improvement activities connected to medical costs, but only for a short specified period, the authors wrote. "A new regulation in this area would be required to enable all of these new and extended ICD-10 conversion costs to fall under the applicable health reform regulations.
“These factors support arguments for a uniform approach to a delay based on a single switch-over date that would allow alternative implementation methods, such as that using SNOMED CT, and that minimizes unnecessary costs and resources,” the authors stated. “However, that would require further regulatory accommodations in related areas. A delay period, with full adoption and use by all stakeholders by 2015, would probably accommodate these factors.”
They suggested that the Centers for Medicare & Medicaid Services use the delay to accelerate its efforts to incorporate SNOMED CT adoption and enhanced clinical documentation, as is already required for clinical problem lists in Stage 2 of meaningful use. This could lead to more accurate ICD-10 coding arising from SNOMED CT-coded details.
“Because Stage 2 of the meaningful use regulations requires SNOMED CT-based problem lists and clinical documentation, such a move would align meaningful-use timelines and the desire to modernize back-end billing systems with ICD-10,” they wrote.
“Similarly, the Department of Health and Human Services should prepare for the future by considering how the subsequent transition to ICD-11 can be gracefully accomplished,” they concluded. “ICD-11 is due to be disseminated around 2016. U.S. stakeholders—including many small practices and hospitals—may not be able to tolerate the current pace of change, and policymakers can make a positive contribution by giving careful thought to the full impact of the information processing challenges ahead.”
Christopher G. Chute, MD, professor of biomedical informatics at Mayo Clinic in Rochester, Minn., and colleagues, wrote on why delaying ICD-10 is important and touched on ICD-11. While the new compliance date has yet to be set, the federal government did delay the Oct. 1, 2013, compliance date for ICD-10.
“We argue, as have many others, that the requirements to meet these specifications—which now includes the requirement to use the Systematized Nomenclature of Medicine–Clinical Terms, or SNOMED CT, for clinical problem lists—constitutes a vast demand on payors’ and providers’ IT resources,” the authors wrote. “Simultaneously requiring the full adoption of ICD-10-CM imposes an unsustainable burden on many.”
Regulatory mandates abound for payors and providers down the line, according to the authors. “New transaction standards for HIPAA that are required by the American Recovery and Reinvestment Act and the Patient Protection and Affordable Care Act (PPACA) impose major changes to most systems that use ICD classifications for payments.” For example, evidence will be specified to support the medical necessity of insurance claims in a new electronic claim attachment standard. The new regulations also will introduce different operating rules for eligibility, claim status and other claims-related transactions, adding to the existing implementation burden.
The impact of other sections of PPACA will impose similar burdens on payors and providers, according to the authors. Health plans soon will be required to endure a certification process related to HIPAA standards and operations. The recent regulations under the PPACA that require plans to pay out in medical claims 85 percent of the premium dollars they collect allow for ICD-10 conversion-related costs to be accounted for as quality improvement activities connected to medical costs, but only for a short specified period, the authors wrote. "A new regulation in this area would be required to enable all of these new and extended ICD-10 conversion costs to fall under the applicable health reform regulations.
“These factors support arguments for a uniform approach to a delay based on a single switch-over date that would allow alternative implementation methods, such as that using SNOMED CT, and that minimizes unnecessary costs and resources,” the authors stated. “However, that would require further regulatory accommodations in related areas. A delay period, with full adoption and use by all stakeholders by 2015, would probably accommodate these factors.”
They suggested that the Centers for Medicare & Medicaid Services use the delay to accelerate its efforts to incorporate SNOMED CT adoption and enhanced clinical documentation, as is already required for clinical problem lists in Stage 2 of meaningful use. This could lead to more accurate ICD-10 coding arising from SNOMED CT-coded details.
“Because Stage 2 of the meaningful use regulations requires SNOMED CT-based problem lists and clinical documentation, such a move would align meaningful-use timelines and the desire to modernize back-end billing systems with ICD-10,” they wrote.
“Similarly, the Department of Health and Human Services should prepare for the future by considering how the subsequent transition to ICD-11 can be gracefully accomplished,” they concluded. “ICD-11 is due to be disseminated around 2016. U.S. stakeholders—including many small practices and hospitals—may not be able to tolerate the current pace of change, and policymakers can make a positive contribution by giving careful thought to the full impact of the information processing challenges ahead.”