No Benefits to a Delay
Although no ICD-10 delay was included in the recently-enacted Sustainable Growth Rate (SGR) reform legislation, some physicians continue to suggest there should be another delay. These words of Mark Twain seem like an apt description of the ICD-10 transition: “Never put off till tomorrow what may be done day after tomorrow just as well.”
After two delays (three if you count the change in the ICD-10 compliance date between the proposed and final rules), it’s very clear that delays have not benefited anyone – even those who have been the staunchest advocates for the delays. Delays have been disruptive and costly for healthcare delivery innovation, payment reform, public health, and healthcare spending. The healthcare industry had already invested an enormous amount of time, effort, and resources in preparing for the transition. Many healthcare organizations expected to meet the 2014 compliance date and were very disappointed and frustrated by the congressional action delaying the transition. Many providers, including physician practices, were on track for the 2014 compliance date. Many payers, including CMS and most state Medicaid agencies, were also on track.
Delays have created wasteful spending, without tangible benefit. CMS had estimated the cost to the healthcare industry of a one-year delay to be as much as $6.8 billion, or a 30 percent increase in implementation costs. A 30 percent cost increase for just a one-year delay is consistent with the experience and observations of Coalition for ICD-10 members. Each delay requires ICD-10 conversion work already performed to be updated, retested, and reintegrated – greatly increasing the cost of conversion. Retraining personnel and reconfiguring systems repeatedly every time ICD-10 is delayed is unnecessarily driving up the cost of healthcare.
Delays also impact academic curricula for health information management and coding programs. It is difficult and costly to modify curricula, and each time the ICD-10 compliance date changes, the curricula have to be re-designed to ensure students are educated in the appropriate coding system in accordance with their expected graduation date. As a result of last year’s delay, thousands of new graduates had to obtain post-graduation training in ICD-9-CM, since the curricula had been updated to include only ICD-10 education, based on the previously-scheduled transition date.
And have these costly delays been beneficial to anyone? Have they helped lagging stakeholders catch up? NO!! The healthcare industry has had six years, including two delays, since the 2009 final rule adopting the ICD-10 coding systems was published. Although the delays provided more time to prepare for the ICD-10 transition, many organizations did not take full advantage of this additional time. Many of the same providers who lagged behind early on in the implementation timeline and claimed they needed more time to prepare are still lagging behind. “The sooner I fall behind, the more time I have to catch up.” (author unknown)
Delays are also not an effective solution for possible post-transition issues cited by ICD-10 opponents, such as concerns about significant financial disruptions for small physician practices. A delay will not eliminate or even diminish the risk of payment delays – since those providers most lagging behind and at greatest risk of being unable to submit timely ICD-10 claims are unlikely to be ready no matter how many times ICD-10 is delayed. And for those who have repeatedly advocated for another delay because they are faced with too many competing initiatives, “Tomorrow is often the busiest day of the week” (Spanish Proverb). As the ICD-10 compliance date has changed multiple times, so have the competing initiatives, regulatory requirements, and project deadlines. As many have acknowledged, it would have been easier and cheaper if the US had implemented ICD-10 several years ago. So clearly, “tomorrow” is not a better time.
At the time the delay was announced last year, many stakeholders, including many physician practices, had made significant progress toward ICD-10 preparedness, were on track to meet the 2014 compliance date, and faced serious setbacks and increased costs as a result of the delay. For those stakeholders who prepared in good faith for each of the previous scheduled compliance dates, the delays have cost them enormous amounts of money on top of their original ICD-10 investment – translating to billions of dollars in additional costs across the healthcare industry. Some organizations that were on track to meet previous compliance dates have fallen behind as a result of the delays, due to challenges including:
- Loss of momentum;
- Loss of stakeholder attention and focus;
- Shifts in priorities;
- Redirected ICD-10 budgets;
- Diversion of personnel to other, more urgent projects;
- Cancellation of ICD-10-related contracts;
- Loss of ICD-10-trained staff due to retirements and other circumstances; and
- Unwillingness to expend additional resources on ICD-10 in the event of another delay.
Recent data from a WEDI survey demonstrates that the last delay negatively impacted ICD-10 progress. Some ICD-10 preparation activities showed actual declines in readiness as compared to last year, and two-thirds of providers reported they had slowed or stopped entirely their transition efforts as a result of the last delay. Uncertainty over further delays was cited as a top obstacle across all industry segments.
Yet despite the evidence showing that delays have only hampered, not advanced, ICD-10 readiness, and substantially increased the cost of implementation for all, some physician groups continue to advocate for yet another delay. To what purpose? Would a delay address any of the concerns regarding the transition that have been raised? Lagging readiness in some healthcare sectors? Concerns about cash flow interruptions? The answer is emphatically “no” – another delay is not the solution. Risk mitigation strategies, such as proper preparation, adequate testing, and contingency planning, are certainly appropriate to ensure a smooth transition, but a delay is not a risk mitigation strategy. Delays are just making the ICD-10 transition more difficult and costly – not to mention the negative impact of delaying the many benefits of using a more modern coding system. In the words of the author Mason Cooley, “Procrastination makes easy things hard, hard things harder.”
The lost opportunity costs of failing to move to a more effective code set also continue to climb every year. In the words of writer Don Marquis, “Procrastination is the art of keeping up with yesterday.” The quality of healthcare data is continuing to deteriorate the longer we fail to replace ICD-9-CM, at a time when the demand for accurate, detailed health information is exploding. The diagnosis and procedure coding systems must keep pace with the rapid changes that are occurring in payment and regulatory systems. All of these changes are interrelated and interdependent. The enormous investment that is being made in Accountable Care Organizations, meaningful use of electronic health records, and value-based payment are all predicated on having a more precise and comprehensive diagnosis and procedure coding system that is up-to-date with advances in medical knowledge and rapid changes in practices and technologies.
There is no reason why any ICD-10 stakeholder should be unprepared for the October 1, 2015 ICD-10 transition date. Since the final rule adopting the ICD-10 coding systems was published in 2009, the industry has had six years, including two delays, to prepare for ICD-10. That is more than enough time for any entity, large or small, to be able to get ready. “The dread of doing a task uses up more time and energy than doing the task itself.” (author and speaker Rita Emmett)
Recent survey data has shown the cost of implementation for small physician practices to be much lower than earlier predictions. CMS and many healthcare organizations have reached out to offer ICD-10 preparation assistance to small providers, and free and low-cost training programs and implementation resources are widely available. Let’s move forward with the ICD-10 transition on October 1, 2015 without further delay and stop making the transition process more arduous than it needs to be. Avoiding further delay in ICD-10 implementation is critical in order to limit implementation costs and be able to start leveraging the opportunities anticipated by the availability of better healthcare data – including the ability to provide the detailed data necessary to accurately measure value for the new value-based physician payment system included in the Medicare Access and CHIP Reauthorization Act of 2015. “Remember, action today can prevent a crisis tomorrow.” (author and speaker Steve Shallenberger)