What's wrong with ICD-10?

It's no secret that I'm a major defender of ICD-10 implementation. It's sort of my job.

I probably could take an anti-ICD-10 position and still get paid as long as I back it up with reasonable arguments.

That's why I don't buy the American Medical Association's arguments citing excessive specificity and an infatuation with ICD-11. I do have an appreciation for physicians' concern with the cost of ICD-10 implementation though.

And I don't see SNOMED as an alternative to ICD-10 coding. It's a lot like thinking that ICD-11 coding will fix all your concerns. Which makes me wonder why Jonathan Handler insists on abandoning ICD-10 implementation. But Handler makes a point worth considering:

"For example, ICD-10 encodes the quadrant in which a breast cancer is located (which has minimal value), but not its estrogen receptor status (which has huge value)."

It reminds me of something I read in a paper arguing for the delay of ICD-10 implementation. The authors cited a lack of genomic information in the ICD-10-CM code set.

Of course this means the ICD-10 codes are not a perfect solution. But abandoning ICD-10 implementation in the hope of a more perfect code set is like not leaving the house because you're waiting for a unicorn to give you a ride.

It does make me wonder what else is wrong with the ICD-10 code set. So I'm asking what are the flaws in the system? I have already listed two such flaws. What I'm not interested in are the usual suspects such as:

  • The sheer volume of codes.
  • The complexity of codes.
  • The cost of upgrading codes.
  • It's not ICD-11.

I'm looking for specific deficiencies in the ICD-10-CM/PCS codes. Perhaps the issues will stack up in a way that dissuades me from believing in ICD-10 implementation. Or maybe it will give everyone an accurate assessment of what to expect Oct. 1, 2014.

What are some specific examples of where ICD-10 coding falls short?