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What does an ICD-10 delay mean for providers, payers, vendors?

By Jennifer Bresnick

Update: The Senate passed HR 4302 by a vote of 64 to 35. Read more here.

The healthcare industry is perched on the edge of its collective seat as it waits for President Barack Obama to sign the SGR patch and ICD-10 delay.  Putting aside the financial impact of the SGR fix that makes up most of the bill, what will those few little lines that would prevent HHS from implementing ICD-10 before October 1, 2015 mean to providers, payers, vendors, and other business partners?

It’s a split decision among providers

The lion’s share of the burdens associated with ICD-10 implementation has always fallen upon providers themselves.  Saddled with costly technology upgrades, complicated training regimens, difficult clinical documentation improvement programs, and an uphill battle just to get themselves in the zone to tackle this tangle of activities, the unfunded mandate has prompted grumbling since day one.  But with less than six months until the October 1, 2014 deadline, many of these obstacles have already built enough momentum to carry well-prepared providers to the finish line in time.

“Further delay of ICD-10 discredits the considerable investment made by stakeholders across the country to modernize healthcare delivery,” said CHIME President and CEO Russell P. Branzell, FCHIME, CHCIO. “Providers have already dedicated significant time and resources in financing, training and implementing the necessary changes to workflow and clinical documentation. Any disruption to the ICD-10 transition at this stage would be detrimental.”

 

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“While the delay does allow for additional time for preparation, it poses a significant financial and resource impact on entities that were heavily invested in the transition,” added the American Podiatric Medical Association in a public statement.

 

And yet the most recent surveys of providers show that more than two-thirds remain deeply concerned about the financial and productivity impacts of the ICD-10 transition, with a February poll by MGMA highlighting worries over cost, technology upgrades, and clinical documentation improvement as major downsides to the 2014 timeline.  The AMA has also continued its fight against the new code set, claiming that its huge member base will suffer significant negative impacts if ICD-10 goes ahead as planned.

“The doctor in a small practice, for example, really needs to be looking at how they’re going to use their time, and how they’re going to use their resources,” AMA President Dr. Ardis Dee Hoven told EHRintelligence in February.  “The timing on this is very bad. Even CMS says that there’s the potential here for significant problems in terms of backlog, dollars not being given to the practices that have already delivered the care, and this is again, another one of those things that can destabilize a physician’s practice.”

Payers seem to be ready to go, but do providers have proof?

Despite the reassurance of an American Academy of Family Physicians (AAFP) survey of the major commercial payers, which claims that big health plans such as Aetna and Humana are ready to go, providers aren’t so sure that they will be able to successfully submit claims and receive timely and appropriate reimbursement.  Medicare has been extremely unhelpful, in many providers’ eyes, by failing to open its arms for adequate end-to-end testing with the industry at large.  The limited end-to-end pilot planned for July may not be significant enough to give the majority of stakeholders a clear idea of what to do when ICD-10 rolls around, says Robert Tennant, Senior Policy Advisor at MGMA, and extra time may be the key to ensuring a successful transition.

“[Medicare is] going to wait until the end of July to conduct their ICD-10 end-to-end testing pilots,” he said. “And then they’ve got to turn around and get whatever information you gleaned from that test back out to the industry in time to do something with it. Should we get an additional year, obviously we are going to be strongly urging CMS to take advantage of the additional time and open up end-to-end testing with whoever wants to do it. Let’s get that information back out there so we can get that feedback loop going, so providers can be ready, should the date be October 1, 2015.”

Vendors may be frustrated or elated by the stalling

Vendors may be another stumbling block for providers who have been trying to squeeze an extraordinary amount of work into a tight and cluttered timeframe.  Distracted and frustrated by the process of certifying their EHR products for Stage 2 of Meaningful Use according to the new 2014 ONC criteria, not all software developers have been able to deliver on their ICD-10 promises to anxious providers.

“Only a tiny percentage of software products have been recertified for 2014,” Tennant points out.  “Well, for the most part, those are the same vendors that need to produce an ICD-10 fix.  So if they’re not ready for Stage 2 and the 2014 criteria, they’re probably not ready for ICD-10.  The main players probably will be, but many, many practices use small vendor products that simply will not provide for ICD-10 codes come October 2014,” he said.

On the other hand, larger vendors like athenahealth, which has claimed to be ready since February, may not see much of a reason to stall for another year when their customers have their tools in hand.  “The moving goal line is a significant distraction to providers and inappropriately invokes massive additional investments of time and money for all,” Ed Park, Executive Vice President and Chief Operating Officer at athenahealth said in a statement. “The issue is even more serious when considered in association with another short-term SGR fix and 2013′s Meaningful Use Stage 2 delay.”

“It is alarmingly clear that health care is operating in an environment where there is no penalty for not being able to keep pace with necessary steps and deadlines to move health care forward. Our system is already woefully behind in embracing technology to drive information quality, data exchange, and efficiency, and delays like this only hinder us further.”

What will CMS be thinking?

The big question, of course, is how CMS will handle the whiplash of this unanticipated turnaround.  As of the publication of this article, HHS and CMS have kept tight-lipped about what they’re thinking, but it can’t be pleasant to be in their position.  After stating over and over again that October 1, 2014 was a hard and fast deadline with no more possibility of a delay, and harping on the potential $6.6 billion impact of another delay, will CMS embrace the potential inherent in an additional year to make the switch?  The opportunities to extend testing to the industry at large and revamp the timelines to reflect where providers are instead of where they should be might be costly, but they will also be helpful to those lagging behind.

Where do you fall on the ICD-10 preparation spectrum?  Are you pleased with the prospect of a delay, or do you want to get it over with?

 

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