The Delay of ICD-10

Apr 16, 2014 | Labs Blog

by Leslie Francis, reprinted from HealthLawProf Blog

As part of the “Protecting Access to Medicare Act of 2014,” Congress provided that DHHS may not set ICD-10 as the code standard before October 15, 2015.  October 15, 2014 had been the day set by DHHS for ICD-10 implementation.  For health care systems that have invested a great deal in being ready for the shift from ICD-9 to ICD-10 in 2014, the delay is likely to be a costly one.  Estimates range as high as $6.6 billion.

“ICD” stands for the “International Classification of Diseases”; a common classification system enables standardized billing, care comparisons, and a common framework within which to observe public health trends.  ICD-10, copyrighted by the WHO, has been in development for over 30 years.  It was endorsed by the World Health Assembly in 1990 and first used in WHO member states as early as 1994.  It was field tested by the American Hospital Association and the American Health Information Management Association over 10 years ago and has been in use in Europe for at least 10 years.  The original federal rule requiring ICD-10 codes was promulgated in 2009, for an original implementation date of 2013.

So why the delay? Many physicians, especially physicians in smaller offices, are concerned about the cost and time involved in learning a new way to code.  They claim that a shift from only 13,000 to over 68,000 codes is unwieldy and unnecessary. They also point out that the WHO is expected to release ICD-11 in the next several years and ask whether it might not be just as well at this point for the US to move straight to ICD-11 when it is available.

But there is much to lose by Congress’s concession to strong lobbying from physician groups.  ICD-10 contains more fine grained diagnoses,  is based on understandings of disease that are rooted in at least more contemporary science than ICD-9, and encompasses new technologies that remain unaccounted for in ICD-9.  It allows for better comparative and public health data.  This is not an issue just for techies. Congress’s capitulation is yet another illustration of why quality and cost effectiveness in US health care are so difficult to achieve.