The American Medical Association (AMA) voted on June 19 to evaluate ICD-11 as a possible alternative to ICD-10 for replacing ICD-9 – saying that it will report back to delegates in 2013 with its findings.
“It is critical to evaluate alternatives to ICD-9 that will make for a less cumbersome transition and allow physicians to focus on their primary priority – patient care,” AMA President-elect Ardis Dee Hoven, MD, said in a statement. “The policy also asks stakeholders, such as the Centers for Medicare & Medicaid Services, to examine other options.”
Practicing the "it can’t hurt to ask" methodology ostensibly worked for the AMA in getting ICD-10 delayed earlier this year. Two unrelated anonymous sources, both well-positioned vis a vis ICD-10, told me separately that even Health & Human Services (HHS) Secretary Kathleen Sebelius was surprised when word came down – from the White House? – that her department was to postpone code set compliance. Take that as an unconfirmed rumor, please. But know that somebody, somewhere, made the delay happen.
To be fair, the AMA could be in a time dimension all its own. HHS is likely to decide whether Oct. 1, 2014 will be the new deadline, or not, well before 2013. Unless HHS pushes ICD-10 further into the future, the AMA may be too late to start calling for ICD-11.
But the World Health Organization in mid-May posted what it calls the beta drafting platform of ICD-11 – meaning work is underway though the process is undeniably nascent.
The AMA is not the only one chanting for ICD-11. A blind reader poll asked Government Health IT readers "Should the U.S. leapfrog ICD-10 and opt for ICD-11?"
Nearly one-quarter indicated “yes” while one-third weighed in with a firm “no.” Given the circumstances, which include the fact that ICD-11 is not yet ready for primetime, the more telling perspective is the 43 percent of a total 115 respondents who voted that “it’s worth considering.”
Matt Murray, MD, a pediatric emergency physician and self-described health IT advocate, contends in a May 17 blog post that CMS “prematurely dismisses the alternative option to forgo ICD-10 and implement ICD-11,” adding that he is “very concerned that this dismissal is published without a comparative analysis of the total costs of each option. And there is good reason to seriously consider implementing ICD-11.”
That’s a point very similar to one MGMA has made – that before mandating ICD-10, CMS should conduct a comprehensive cost-benefit analysis, pilot ICD-10 and fully evaluate alternative approaches.
“Implementing ICD-10 has been compared to buying a Betamax instead of a VHS recorder in terms of pending obsolescence,” Murray wrote. “Informatics experts are in agreement that ICD-11 is superior to ICD-10 and that we need to get to it as soon as is tolerable.”
Must we repeat errant history?
The oft-evoked argument for adopting ICD-10 is the matter of timing. It took the United States nearly 20 years to make the clinical modifications for ICD-10 to work on our soil, so we would not be able to tailor ICD-11 accordingly for decades.
But why would ICD-11 have to take so enigmatically long?
To answer that, I asked Jon Lindekugel, president of 3M Health Information Systems; 3M being the company to which CMS essentially outsourced the lion’s share of ICD-10 clinical modification work.
“As you move from one set to another there is a significant multi-year timeframe to create that magnitude of content but it certainly isn’t in the decade timeframe,” Lindekugel told me. “You just look at the timeline and how long I-10 has taken, it took much more time politically to get agreement than it did to create the content.”
So, rather than being hung-up about how long modifying ICD-10 took as some unshakable precedent for ICD-11, perhaps it would wiser to ask whether we as a nation can avoid succumbing to the same errant history that currently has our healthcare system on a classification system one incarnation behind most other developed countries, and take a new tack for the sake of adopting not an aging classification system but, instead, a cutting-edge iteration that is worthy of the enormous shift such a conversion demands.
Readiness or not
Health entities running behind the recommended timelines are not ICD-10 outliers. Not even close.
WEDI’s latest survey, published after HHS proposed the compliance delay, was impressive in that it garnered responses from 2,118 providers, 231 vendors and 242 health plans – and found an industry adrift en route to ICD-10.
Only about one-third of health plans have completed their assessment, and a quarter are less than halfway done, WEDI determined. Worse, among providers nearly half did not even know when they would complete the impact assessment. That’s right: assessment, as in the early step concerning what ICD-10 will require, prior to implementation, internal testing, external work with partners, actual compliance.
Even providers and payers that want to begin are bootstrapped by technology vendors, about half of whom are not yet halfway through product development, WEDI found, while a paltry one-third could say they plan to start customer review and beta testing before the second half…of this year.
No matter how much we hear and read the cries that delaying ICD-10 would only punish those payers and providers that have already invested millions in the transition, WEDI’s statistics belie the reality that healthcare, as an industry, is not overwhelmingly prepared to meet the mandate on time, be that the first day of October in 2013 or 2014.
Why? Or why not?
Since ICD-11 could be modified in a markedly shorter time than ICD-10, and since approximately half the industry is not in shape to cross the ICD-10 finish line, why can’t the U.S. skip ICD-10 and transition directly to ICD-11 once it’s ready?
Before dragging the entire U.S. health system through the mammoth and incredibly expensive once-in-a-generation ICD-10 conversion, we as a nation really ought to be asking, and answering, that simple question.
But here’s what I expect to happen: AHIMA will fire back, urging HHS to stick to its guns, finalize a one-year delay as soon as possible, and ICD-10 supporters will publicly step into line, saying that ICD-10 is a “bridge” or some sort of “stepping stone” to ICD-11.
“Perhaps the optimal pathway to ICD-11 really is through ICD-10, but we need a more comprehensive analysis to make a better-informed decision,” Murray wrote. “Let’s put on the table the total costs and impact of both pathways and then decide.”