Let me start with a prediction – if CMS’ Proposed Rule simply mandates an industry-wide compliance with ICD-10 as of October 2015, ICD-10 will eventually be delayed again.
As CEO of a consulting firm that has been assisting dozens of hospitals and health systems responsibly prepare for ICD-10 readiness, this is an incredibly frustrating and unfortunate prediction to offer. The majority of the healthcare industry was fully committed heading into this past spring to complete the transition this year – there obviously would have been problems and challenges that would have been worked through, but the momentum and collective commitment towards a single objective had never been higher than it was prior to the legislative delay.
While we wait for CMS to publish their Proposed Rule that is anticipated to just re-establish the new compliance date of October 2015, the majority of industry discussions have been centered around – “keep the momentum going,” “continue testing,” and “educate physicians on why this is good.” These are all worthwhile tactical discussions, but are increasingly being evaluated against the more pressing and strategic needs of each organization. Focus on ICD-10 continues to get pushed down on the already long lists. More importantly, none of these discussions will reduce the likelihood of yet another delay being lobbied for and implemented, since they do not address the underlying concerns of those who lobbied for delay.
At the core of the most effective lobbying is a subset of the physician community that was not sufficiently motivated by the incentives associated with HITECH and Meaningful Use to implement compliant EMR systems within their practice operations. Without trying to understand and address this community’s concerns, the government and industry have no chance of getting them to support a mandated regulatory change, like ICD-10.
The only way that the industry has a chance to avoid the crippling impact of annual resets on the compliance date is to push CMS and the payers to support a creative implementation approach that is incentive-based, and allows those who choose to “be left behind” on ICD-9 – at least for some transitional period of time. For example, make October 2015 the start of when providers can choose to begin to send claims and reporting data in ICD-10 format. Will there be complexity and issues with a hybrid model? Absolutely. However, is the alternative of never advancing off ICD-9 better? The calls for “let’s wait for ICD-11” ring hollow, since the same mandated implementation issues will exist and need to be addressed then. The industry was so close this year before having its collective legs chopped out from under them. It would be a complete reset sometime in the next decade or longer before ICD-11 would realistically be ready and be considered.
How do the influencers and thought leaders within the industry elevate the dialogue to start looking at changing strategies for transitioning to ICD-10, rather than just on the current preparation tactics?
The fear is that unless that dialogue can get started quickly in a meaningful way, we should expect more of the same – CMS announcing a mandated date in 3Q, and then lobbyists succeeding in 1Q next year to get another ICD-10 delay added to the 18th annual Medicare SGR fix. We can and need to do better.
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