Healthcare Revenue Cycle Management, ICD-10, Claims Reimbursement, Medicare, Medicaid

Policy & Regulation News

Coalition for ICD-10: ‘It is Time to Move Forward with ICD-10’

By Jacqueline DiChiara

- With $22 billion spent by the healthcare industry over the past two decades to plan, train, convert systems, test, and transition for ICD-10 implementation, and a delay costing over $6 billion, will the healthcare industry ever be ICD-10 implementation ready?

ICD-10 delay

Opinion is mixed. The Coalition for ICD-10 has responded to a recent report from the Heritage Foundation urging Congress to isolate reimbursement policy from the ICD classification system. ICD creates an excessively laborious billing process, maintains Heritage Foundation authors John Grimsley and John S. O’Shea, MD, who promote the impediment of ICD-10 implementation. Contrastingly, the Coalition for ICD-10 maintains ICD-10 opponents have expressed the need for more time to implement regularly for the past 20 years. 

Highlights of the Heritage Foundation report

“The mandatory adoption of the latest International Classification of Diseases (ICD-10) will add to the already considerable financial and administrative burdens on physician practices,” state Grimsley and O’Shea, who advocate for a more appropriate diagnosis coding system. “Instead of imposing this unfunded mandate, Congress should delink the disease classification system from reimbursement policy, and make the adoption of the new ICD-10 code system voluntary until a less burdensome billing process is in place,” they add.

Grimsley and O’Shea maintain explanations in support of ICD-10 implementation are merely “weak” – i.e. the need to update dangerously antiquated clinical data, international lag behind other nations already implementing ICD-10, and claims of upcoming improved patient care. Following costly ICD-10 implementation, healthcare providers will struggle with long term loss of revenue and declining reimbursement, Grimsley and O’Shea maintain. The ICD-10 transition has created a complex situation for practicing physicians. It has become a complicated policy situation for lawmakers, and Congress.

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The ICD system must be delinked from reimbursement policy, confirm Grimsley and O’Shea. Congress can improve medical reimbursement, they state, by correcting their “misguided decision to conflate research goals with the reimbursement process.“ Within three years, Congress should establish an alternative arrangement for reimbursement that is separate from the ICD disease classification system. Congress should, with input from the private sector and the medical profession, develop a reimbursement process that is flexible enough to accommodate future advances in medical technology without periodic disruptive overhauls,” Grimsley and O’Shea state.

Additionally, Grimsley and O’Shea confirm healthcare providers should be granted the option of choice regarding ICD-10 implementation. “As Congress develops a more appropriate coding system for billing purposes, providers should have the choice of using the current ICD-9 or the updated ICD-10 system,” they state. “Those providers who choose to remain with the ICD-9 could do so without penalty,” they add, referencing the substantial investments many physician practices have made to prepare for ICD-10.

“This unfunded mandate not only perpetuates a misguided policy decision that confuses the disparate goals of research and reimbursement, but adds a significant financial and administrative burden on physician practices, especially smaller practices that do not have the resources to absorb the costs of transition,” the authors conclude. “Congress should, through an equitable transition process, take this opportunity to delink research from reimbursement, abandon the mandatory implementation of ICD-10, and pursue the development of a billing system that is specifically designed to make the reimbursement process less, not more, burdensome for physicians and other health care providers,” they add.

Highlights of the Coalition for ICD-10’s response

According to the Coalition for ICD-10, the aforementioned arguments are merely a rehash of sentiments made within the past two decades. “The proposals put forth in the report would not only result in the loss of enormous investments that have already been made, but would require extraordinary additional investments,” the Coalition states, in reference to the Heritage Foundation's ideas.

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The Heritage Foundation report, says the Coalition, ignores the fact that physician reimbursement is manifested via other classification means aside from ICD, such as CPT codes and CPT modifiers.

“Up to four CPT modifiers can be reported with each CPT code resulting in essentially a limitless number of possible unique CPT code and modifier combinations,” claims the Coalition. “Why is it that CPT codes are not viewed as overly burdensome, but ICD-10 codes are?”

The benefits of dual system coding are nil, the Coalition maintains, referring to dual coding as merely “unworkable, costly and confusing.” With the ability to weaken the data infrastructure of the healthcare industry, dual coding would mean the execution of expensive changes to major payment, clearinghouse, and provider systems, the Coalition says. 

“We must end two decades of delay tactics,” the Coalition states, in reference to the tens of billions of dollars already invested by hospitals, health plans, providers, researchers, coders, federal and state agencies, vendors, device manufacturers, and many others. “It is time to move forward with ICD-10.”


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