ICD-10 Delay: Good, Bad or Ugly?

If you work in healthcare you’ve probably heard about the potential to delay ICD-10 until October 2015.  The long anticipated vote was taken up by the Senate on the evening of March 31st when they voted to approve H.R. 4302 temporarily heading off significant cuts to the Medicare Physician fee schedule and delaying ICD-10.  The final step is the President’s approval.  What does this mean?  Should we be cheering or lamenting this new reality?  As someone who has spent a majority of the last two decades in healthcare, I am truly torn about this delay. I’ll share with you why…

PROS to the ICD-10 Delay

ICD-10 implementation is going to be a costly endeavor for ANY size organization.  The change in code sets plays a significant role in identifying disease and illness but learning them may be a daunting task for even experienced coders.   ICD-9 seems like a basic tool compared to the expansive and detailed requirements of correctly using ICD-10 codes.  With that in mind, having another 18 months to prepare feels like a really, really good thing.

1.    The delay will help providers become more familiar with ICD-10

Providers and their staff need to learn the ‘translation’ and expanded code set which is a difference of TENS of THOUSANDS of codes.  Taking this time to crosswalk from codes used in ICD-9 to ICD-10 could take months for providers to become more comfortable.

2.    Testing the systems would be more thorough

It wasn’t until last month that CMS was even willing to do end-to-end vendor testing on the new code set and that wasn’t scheduled to be done until August prior to go live in October.  With this new timeline testing can be more methodical, ensuring success for the possible October 2015 implementation.

3.    More time for financial preparations

Regardless of when the new code set goes live, the sheer increase in complexity and volume of codes is anticipated to negatively impact practice revenue.  Some experts have suggested a reduction in payments (between actual denials and delayed payments) to the tune of 25%!  The increase in time before implementation allows providers to make financial preparations, in the form of a cash reserve more attainable.

CONS to the ICD-10 Delay

On the other side of the coin, there are some real drawbacks to the delay of ICD-10, and we should all think honestly about how this change affects our work and plan for next steps.

1.    ICD-10 preparedness urgency will disappear

Rejoicing in the delay may lead to a return of ‘business as usual’ and in a year we’ll be in the exact same panic many people experienced until the recent vote.  I fear people will not use this time wisely, lessons will not be learned and it will be a bad version of the Bill Murray’s movie Ground Hog Day.

2.    Another year of missed data

One of the benefits to appropriate and accurate use of ICD-10 is the data mining capabilities that many around the world have found through using this code set.  ICD-10 has been in place throughout the world for many years specifically for the disease research opportunities of having such a defined coding system.  With another year delay our rich healthcare data cannot be used and compared on a global level to assist in the efforts to better understand and prevent disease.

3.    Real loss of time and money

For those who ARE ready for ICD-10 the financial impact and opportunity cost of their efforts is very real and now gone.  Frustration in how politics impacts healthcare policy and initiatives may lead to increased apathy in the very talented leaders of this industry who are dedicated to moving it forward to a better place.  A delay like this may just send them into another field, or worse into a state of inaction.

The reality is yet another delay of a major healthcare initiative; it impacts everyone in different ways-long term and short term.  After the initial relief or anger wears off, I wonder where we will end up.  How will the healthcare industry take this and learn? Will we take this knowledge and use it to improve the overall structure of our healthcare delivery system? Only time will tell…

Kristy Brown, MBA, PT
Vice President, MBA HealthGroup