Implementing ICD-10 Coding System Will Require Preparation, Prompt Action

Health care clearinghouses, hospitals and providers received a clear message on August 22 when the U.S. Department of Health and Human Services (HHS) published the proposed regulations calling for the replacement of ICD-9 code sets with ICD-10. The transition is likely to be challenging and expensive, with an estimated price tag of roughly $1.6 billion (for training, lost productivity and systems change costs) and an implementation deadline that is just a few years away.

In the proposal’s preamble, HHS states that the change is needed because the ICD-9 code sets have space limitations, require workarounds to the structural hierarchy of the coding system, lack sufficient detail to support diagnostic and quality reporting and do not allow for global communication of mortality reporting and biosurveillance information. “The lack of specificity in ICD-9-CM…limits our ability to develop rapid interventions for emerging diseases affecting international populations,” according to HHS¹.

Health care entities should embrace the HHS goals for adopting ICD-10 and immediately begin preparations for the proposed Oct. 1, 2011, implementation date, according to Anita Hart, RHIA, CCS, CCS-P, product manager for Ingenix.

“Across the industry, we need to bite the bullet and get to work planning implementation strategies for this massive transition from
ICD-9 to ICD-10,” she advised. “Smart stakeholders will move immediately to assess their current coding operations, learn more about the new code sets and plan for the conversion and its ramifications.”

Benefits of ICD-10 transition are many

The proposed mandate for the adoption of
ICD-10-CM and ICD-10-PCS, the respective standard code sets for diagnoses for all entities and procedures for hospital inpatients, should not come as a surprise to the health care industry, considering that the World Health Assembly adopted these code sets in 1990.

“We can’t really say we’ve been blindsided by this regulation,” Hart said. “ICD-10 has been around for nearly two decades, and the industry knows that ICD-9 no longer is meeting its needs.” Hart pointed out that the ICD-9 system, which consists of 17,000 codes, cannot accommodate the growing need for diagnosis and procedure specificity. By comparison, ICD-10-CM/PCS consists of 155,000 valid codes.

Further, the federal government is under global pressure to adopt ICD-10 and is unlikely to delay the transition for much longer. “Right now, the United States is limited in its participation in global community biosurveillance initiatives because we have failed to move forward with the rest of the world,” she asserted. 138 countries have already adopted ICD-10.

She added that the investment involved in moving from ICD-9 to ICD-10 will deliver substantial benefits on a national level as well. The more descriptive and well-categorized codes will offer diagnosis classifications that better represent the severity of disease, increase the capacity to report quality measures, improve interoperability of electronic health records, and support more equitable reimbursement and higher-quality patient care. The ability to report greater specificity for procedures and services also will significantly improve tracking outcomes data for new technologies and treatment.

In HHS’ view, adoption of ICD-10 is critical to the success of other vital health care initiatives. “The ability to modify or add to a list of treatments, diseases and conditions is essential,” HHS states, for “quality improvement programs to effectively result in meaningful clinical outcomes, improved practice management processes that document and measure patient care, and…provider investment in services that improve quality of care."²

Preparing now will make a difference

Hart is concerned that some stakeholders in the health care industry will not act promptly on the new regulation. “It’s a real business risk to delay preparations for the change, hoping that the final rulemaking process will push the deadline further into the future,” she said. Despite the fact that many entities will oppose the effective date in their comments on the notice of proposed rulemaking, Hart noted that “this is one transition that can’t be handled at the last minute.”

She believes that the industry must get started now, even without a final rule. “How you lay the foundation for ICD-10 at your organization may very well determine how successfully you handle the financial and productivity impacts in the first years of implementation,” she said. Providers, hospitals and clearinghouses can minimize transition problems and realize benefits more quickly from the more precise and comprehensive coding systems by planning ahead and using innovative technology.

How to begin? First, advised Hart, “become familiar with the new code sets, even in their proposed form.” Ingenix has published two books that preview the structure and conventions of ICD-10, one for the CM version and one for the PCS version.

“When you take a closer look at the code sets, you’ll get a better feel for the challenge. As professionals, we will still code diagnoses and procedures as documented in the medical record, but use different codes,” she said. “The basics of coding remain the same, but we will need to learn new tricks, such as terminology and specificity of body parts. Also, we must continue to educate regarding documentation issues.”

Next, plan your navigation between the old codes and the new. Hart stated that it is a technology vendor’s job to create mapping tools to help code users manage the change. She noted that there will be no clean “crosswalk” between ICD-9 codes and ICD-10 codes. “For example, one ICD-9 code might map to 12 more specific
ICD-10 codes. Mapping can offer code possibilities depending upon the information provided and the use of the coded data. Ingenix is creating mapping tools for launch in 2009 that will provide ‘yes or no’ questions, choices and lists to help guide users to the right code for the situation,” she explained.

Establishing a solid foundation in 2009 will enable stakeholders to implement the right vendor tools, test and refine systems, and then focus their attentions on coder and data user training in 2010. One of the biggest hurdles in the training area, Hart indicated, is for coders to understand the challenges for translating the medical record information into the appropriate codes.

“On some level, coders already have been growing accustomed to the new specificity and terminology,” Hart said. Recent ICD-9 updates have been aligned to or have mirrored ICD-10 codes in this respect. “The bottom line is that ICD-10 presents a learning curve, but with adequate process and systems preparation in 2009, stakeholders will have more than two years to overcome that hurdle.”

Entities also must consider the proposed rule’s impact on their industry partners. The coding change will affect software systems of both providers and payers, including billing and payment, clinical systems (e.g., electronic health records, personal health records), decision support and other ancillary systems, as well as clinical and billing workflows and payment methodologies, among other key functions, according to Hart.

Moving forward

Given the HHS position that “conversion to ICD-10 is essential to development of a nationwide electronic health information environment,”³ substantial delay of the
ICD-10 final rule is unlikely, even in light of the significant number of public comments that are slated for submission regarding the proposed rule. “Regardless of when the ICD-10 final rule comes out, or the final implementation date, ICD-10 is coming,” Hart affirmed. “There is intense pressure both from the federal government to make our coding system more efficient and value-based, and from the international community to partner effectively in global biosurveillance.”   

To prepare for the regulation, health care stakeholders must “assess their needs, create task lists and get moving,” Hart said. “There is a great deal of work ahead to transition clearinghouses, hospitals and providers to ICD-10, but with a solid plan and innovative technology, the changeover will seem less daunting.”

She concluded, “The health care industry isn’t facing this alone. Ingenix is creating the tools to ease this transition. We have been a leader in this business for a long time and have the expertise to help.”

¹“HIPAA Administrative Simplification: Modification to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS,” HHS Proposed Rule, 73 FR 49800 (Aug. 22, 2008).
²Id.
³“HHS Proposes Adoption of ICD-10 Code Sets and Updated Electronic Transaction Standards,” U.S. Department of Health and Human Services Press Release quoting HHS Secretary Mike Leavitt (Aug. 15, 2008).

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