With CMS confirming that they are considering a delay in the final mandate for ICD-10 past the October 1, 2013 current deadline,  there are some discussions going on about skipping it entirely in favor of ICD-11.

Some things about ICD-11 – The base version from WHO is expected in May 2015.  After that, the United States will probably need another two years for development of the US version.  The earliest it would be available for study would be 2017, and we would need another 4 years to implement it – so that brings us out to 2021, way too far in the future.

Second and most importantly, we do not favor penalizing the companies that have started work on time on ICD-10.  The health care industry has spent hundreds of $millions already on ICD-10 education, assessments, etc.  Some hospital organizations are not happy about the delay, either.

It would be best for health plans, hospitals, and physicians to use the extra time to implement ICD-10 correctly.  There are consortiums that have sprung up to help with this effort.  We’ll be discussing this more at HIMSS 12 this week in Las Vegas, NV.

Discussion has been that ICD-10 is a steppingstone to ICD-11, so it is probably a good thing to do.  Also, ICD-9 has about had it, so we can’t see keeping it around another 10 years.  Note that ICD-10 procedure codes have nothing to do with the diagnosis codes or ICD-11, so that is a non- factor.  The ICD-10 procedure codes for use in hospitals are a significant improvement.

The theory of a staggered start to ICD-10 has also been floated – that CMS might continue to mandate the October 1, 2013 date for some plans or providers while offering relief to others.  One theory is that smaller entities or rural providers might get relief.   This seems equitable – that those who have invested in ICD-10 and can afford to meet the ICD-10 date would continue on their current path, while those who cannot afford it get a break.  However if one considers the national impact of a staggered start, it means that payors would have more dual processing of ICD-9 and ICD-10 claims to consider, based on a new factor – size of the provider and perhaps their location.  Would this relief really help or cause more havoc?  We’ll all learn more when CMS clarifies their statement that “certain entities” might be impacted.

There are clear benefits in our mind of ICD-11, including SNOMED CT clinical vocabulary supporting Electronic Medical Records.  However, the ICD-10 train has left the station.  It should be arriving – just later than scheduled.

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