Texas Representative Ted Poe has introduced H.R. 2126, the Cutting Costly Codes Act of 2015. This legislation would prohibit the federal government from requiring physician offices to comply with the proposed transition to ICD-10 codes. “The new ICD-10 codes will not make one patient healthier," Representative Poe said. "What it will do is put an unnecessary strain on the medical community who should be focused on treating patients, not implementing a whole new bureaucratic language.” He has clearly listened to the Texas Medical Association (TMA) which has consistently advocated for postponement of ICD-10 on behalf of 48,000 physician members.
I am one of those Texas physicians who is thankful that a congressman has listened to us. If this bill were passed it would postpone ICD-10 and call for the GAO to study the issue, but it does not propose any solutions. Although I am in favor of this bill, I agree with the cry of many healthcare stakeholders that we need a solution to move away from the antiquated ICD-9 codes. It seems likely that a bill that does not propose an alternative solution will have difficulty getting passed.
I am hopeful, though, that debate about this bill might illuminate two major flaws in national health IT strategic planning. The current ICD-X strategy which includes no roadmap to ICD-11 will set up the U.S. healthcare industry for strife and conflict in the 2020s when we see the rest of the world leveraging integration between ICD-11 and SNOMED to improve quality of care and control costs while we struggle to gain value from what will then be an antiquated ICD-10 coding system.
The first flaw is the lack of a strategic plan or roadmap at a national level for ICD-X conversions. For example, there is no mention of ICD-10 or ICD-11 planning in ONC's Federal Health IT Strategic Plan 2015-2020. It is difficult to trust a strategic plan that fails to account for the tremendous burden that an ICD-10 and/or ICD-11 conversion brings to the healthcare industry. The ICD-10 tactical delays can be directly attributed to conflicting strategic national healthcare priorities which resulted in an overlap of initiatives at the local level--eRx requirements, Red Flag Rules, HITECH/HIPAA, Meaningful Use stages, PQRS, ambulatory EMR purchases/implementations/upgrades/updates and other healthcare regulations--and created unreasonable, concurrent burdens on physicians. Tactical delays like this can be avoided through more effective strategic planning at the national level.
It is particularly disconcerting that there is no national roadmap to ICD-11. As I previously wrote, the U.S. is planning to achieve a short-term tactical goal of replacing antiquated ICD-9 codes while the rest of the world is closing in on their long-term strategic goal of implementing ICD-11. Informatics experts are in agreement that ICD-11 is superior to ICD-10 and is much more integrated with SNOMED codes. In the 2020s I believe we will see the rest of the world successfully leveraging the benefits of ICD-11 and its tight integration with SNOMED to improve quality of care and control costs, while the U.S. is struggling to gain value from what will by then be antiquated ICD-10 codes. Cries for ICD-11 will crescendo, with most cries coming from those who do not see patients everyday. Without an ICD-11 roadmap, we will be destined for the same predicament, only this time struggling with a short-term tactical goal to replace last century’s ICD-10 codes with no strategic plan in place to align that burdensome effort with other healthcare priorities.
The second flaw is the lack of an effective process during ICD-X conversion planning to identify and address the concerns of grass root physicians who see patients every day. Failing to address physician concerns prior to developing the ICD-10 solution to the replacement of ICD-9 was a strategic blunder. Perhaps the most significant physician concern is the tremendous burden placed on physician practices by the ICD-10 conversion. Optimal planning on how to replace antiquated ICD-9 codes really should include discussions on how we might best reduce or avoid that burden. At the very least, we should discuss how best to reduce that burden in the future, because physicians see ICD-11 coming around the corner.
For example, we should discuss the possibility of converting from use of ICD-9 or ICD-10 to use of SNOMED codes in physician practices. Physicians would not have to learn new ICD-X codes each time administrators decide a conversion is necessary. Use of SNOMED codes mapped to ICD-X codes would be less disruptive to physician work flow and be more cost effective for physician practices as compared to complying with future ICD-X conversion mandates.
The analysis on how best to resolve the ICD-9 problem should address physician concerns and result in a strategic plan that is determined to have the highest potential to improve healthcare quality at the lowest cost. So what are some attributes of the optimal strategic planning effort? It would be included in ONC's federal health IT strategic plan. It would include a national roadmap to ICD-11. It would include a comparative analysis of the cost/benefits of completing a conversion of ICD-10 versus a direct conversion from ICD-9 to ICD-11. It would include an analysis of the potential to replace ICD-9 or ICD-10 codes in physician practices with SNOMED codes. And it would include a process to identify and address the concerns of physician practices throughout the planning stages.