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What Does the Potential ICD-10 Delay Mean?

March 28, 2014

ICD-10 4 Minute Read

In a move that everyone expected, the House of Representatives approved this year’s SGR fix bill on March 27th. In a move that no-one expected, that legislation has bundled in a one year delay of ICD-10 implementation.

For reference, the bill addresses the Sustainable Growth Rate formula. Without a fix, Medicare physicians face a 24 percent reimbursement cut beginning April 1. The debated bill, H.R. 4302, introduced by Joseph Pitts (R-Pa.), proposed replacing the reimbursement cut with a 0.5 percent payment update through the end of 2014, and a zero percent payment update for the period of Jan. 1 through March 31, 2015. The bill is believed to be a result of agreement between Senate and House Leadership, and is unlikely to face significant resistance in the Senate when the vote comes to the floor on Monday the 31st.

The House moved to pass the bill by a verbal vote this week, until the lack of understanding around the bill was addressed. Representatives stated their concerns:

Sandy Levin (D-MI) claimed,“This bill is very disappointing — we got this bill just 24 hours ago.” Levin said serious discussion on a permanent SGR fix is needed. 

“I challenge any member to come up here and say I have read this bill,” said Rep. Steny Hoyer (D-MD). “None of us know what the substance of this bill is. We do not have the courage to rationally fund that agreement. This is a game unworthy of this institution and the American People.”

It isn’t just politicians that have concerns over the bill — CHIME and a number of CIOs are unhappy about the recent developments and voiced their concerns in an article on FierceHealthIT. 

What does this all mean? Who will be affected and what impacts will the delay have, if the bill is passed? Thomas Grove, one of Phoenix’ ICD-10 experts, shares his thoughts:

If this delay comes to pass, what are the effects on providers?

  • We all get more time (but not all will use it wisely). This is a lesson learned from the last delay. Some providers will continue to work aggressively on ICD-10, and others will channel their scarce resources to Meaningful Use / MIPS and other projects, and put ICD-10 on the back burner until it becomes urgent again.
  • We get more testing (maybe). One of the concerns most consistently voiced by those working with ICD-10 on a regular basis is that there has been a lack of coordinated testing activity between providers and payers. Until recently, CMS refused to do any testing at all, and still only expects to perform end-to-end testing in July with a couple dozen providers.
  • We lose the benefits of training we’ve already conducted. Most hospitals have already begun training their coders in the intricacies of ICD-10, and will now find themselves needing to either retrain those staff next year, or make significant time available in the upcoming year for coders to practice and keep their ICD-10 skills fresh.
  • It will cost some of us money. Some providers have already hired coders (or negotiated service contracts) for coders that we don’t need for another year. Hopefully those who have hired outside services have an appropriate delay clause in their contracts, but those who have already hired and trained coders are unlikely to let them go, and so will incur that cost. Services that charge annually, like subscription training or coding resource websites, will also add cost.

What steps should providers take?

  • Assess the current state of major IT projects in the organization. Some project priorities will change, and while it probably doesn’t make sense to put off upgrades for a year, it may make sense to shift some dates to more critical projects, such as Meaningful Use / MIPS.
  • Assess the current state of ICD-10 training. Training that hasn’t begun can probably be delayed, but the extensive training that coders require is already underway, and key decisions will need to be made about how to maximize the value of dollars already spent (or committed).
  • Assess contract services. Review services contracted for, such as training and resource websites to determine the best strategies for dealing with those commitments in the upcoming year.
  • Assess staffing levels. Organizations that have already begun staffing up for ICD-10 will be overstaffed without the demands of ICD-10. The additional staffing may be reduced through attrition, but many providers will not choose to actively reduce staff, and instead must identify valuable activities for these excess resources to perform, such as dual coding for training, documentation assessments as part of a Clinical Documentation Improvement Efforts, or additional quality oversight of existing coding activities.

All of us will be waiting for the results of the vote on Monday, but it looks probable that we will be facing a new set of unexpected challenges. If the delay comes to pass, it will release the pressures on those who are unprepared for ICD-10, but it will penalize those who are prepared. What kind of message is that sending to healthcare providers? What are the largest impacts you anticipate having to face if ICD-10 is delayed, yet again?


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