CMS Has Finalized the ICD-10 Compliance Date, But Does It Even Matter?

Late in the afternoon on July 31, the Centers for Medicare & Medicare Services (CMS) made an announcement that the compliance date for the ICD-10 transition would officially be October 1, 2015. While some groups were pleased that CMS made their announcement, many in the industry held their collective breaths—and for good reason.

Back in April, various industry associations were calling for the federal agency to make the announcement as soon as possible, as confirmation of the date would give organizations the time to appropriately prepare for the new coding system. “While the transition to ICD-10 remains inevitable, it is extraordinarily difficult for organizations to make the proper preparations and investments without knowing the implementation date,” Lynne Thomas Gordon, CEO of the Chicago-based American Health Information Management Association (AHIMA), said at the time. “The announcement of the new implementation date will give the industry the clarity necessary to prepare in the most cost-effective, prudent and strategic way.”

That statement made by Thomas Gordon was in mid-April, only a few weeks after the third delay of the compliance date for the transition to the new coding set was announced. It took three-and-a-half months for CMS to confirm the new deadline to indeed be Oct. 1, 2015.

Last week, in its announcement, CMS stated, “This deadline allows providers, insurance companies and others in the healthcare industry time to ramp up their operations to ensure their systems and business processes are ready to go on Oct. 1, 2015.” Even the headline of the CMS release—“Deadline for ICD-10 allows healthcare industry ample time to prepare for change”— reeked of defensiveness, as if the agency knew what everyone was thinking: “What the heck took so long?”

So now, please forgive me and the rest of the health IT world for our collective skepticism regarding the just-announced Oct. 1, 2015 deadline. I wholeheartedly agree with what my colleague, Gabriel Perna, HCI’s Senior Editor, tweeted out after the July 31 announcement:

After the delay was confirmed in April, Perna wrote a blog expressing his disappointment in the government for pushing the deadline back yet again. In that blog, Perna quoted a line from Marilyn Tavenner, R.N., CMS administrator, who got up in front of a crowd at the Healthcare Information and Management Systems Society (HIMSS) conference in Orlando in February and said, "By now, folks understand that there will be no more delays. Let's face it guys, we've delayed it more than once and it's time to move on."

I actually believed Tavenner. But the old proverb says, “Fool me once, shame on you; fool me twice, shame on me.” Now this is three times. Why shouldn’t we expect a fourth?

"I've been burned too many times over the past few years," Roger Neal, vice president and CIO of the Oklahoma-based Duncan Regional Hospital, told FierceHealthIT last week. "We were ready last time and wasted a ton of money when the final deadline got moved ... this time [we] will limit our cash exposure so we don't waste another million plus."

Although ICD-10 isn’t exactly the sexiest, most glamorous thing to talk about in healthcare, it’s still very significant, and providers have expressed some interesting views on the transition. For starters, the new coding system will have about 68,000 codes to describe diagnoses and treatment, compared to 14,000 codes in the existing ICD-9 system. There are even codes for getting bitten by a turkey or injured by a squirrel! Seriously, check out that link—you will be amazed by what there are medical codes for.

As such, many medical professionals simply don’t see the need for such a granular coding system. At HIMSS14 in Orlando, I asked Howard Landa, M.D., CMIO at the Oakland-based Alameda County Medical Center, and vice chairman of AMDIS (Association of Medical Directors of Information Systems), about the burden of federal mandates on providers, including ICD-10. “If physicians see value, that's one thing, and they will get on board. But no one sees value in ICD-10. I want to believe that better data will lead to better care—I've staked much of my life on that. But I'm starting to get more and more cynical. ICD-10 is a big reason why,” he said.

Included in that skepticism is the cost that it takes to transition to ICD-10. One study funded by the American Medical Association (AMA) estimated that it could cost doctors’ offices $56,000 to $8 million to transition to ICD-10, depending on the size of the practice. The AMA has been completely opposed to implementing the code set from the beginning.

While I won’t argue today about whether ICD-10 is worth the trouble, the point is that because of the repeated delays—as well as misinformation and lack of direction from the government— and the costs that come with them, it is trouble for organizations. The feds can spin it so it looks like they gave providers enough time to get ready for the new deadline, but I, for one, am not buying it. Nor will I buy it if Tavenner says at next year’s HIMSS conference, “There will be no more delays.”

I made that mistake last time. Now, I’ll only believe it when I see it.