"The decision to mandate ICD-10 for covered entities has already been made."
This response in the ICD-10 final rule published last Friday by the Department of Health and Human Services (HHS) bluntly spurns the option of foregoing ICD-10 to implement ICD-11. HHS predictably argues that the considerable investments already made by healthcare organizations into ICD-10, the years of rulemaking with previous analyses of ICD-10 value/costs and the "uncertainties" over the timeline and value of ICD-11 all justify a decision to eliminate ICD-11 as an option.
I am disappointed that HHS made no estimates on the comparative value of ICD-10 to ICD-11. Instead of comparing the total cost of proceeding with ICD-10 and then implementing ICD-11 to the total cost of foregoing ICD-10 to implement ICD-11, HHS candidly explains that "we do not participate in this debate in this rule, except to say that we are convinced of the benefit of ICD-10 to health care delivery in this country." There clearly was no intent to revisit a previous decision to implement ICD-10, even though there is an opportunity to gather and analyze new information to assure we make an informed decision on the optimal pathway to an inevitable ICD-11 implementation.
The final rule dismisses the call from several commenters on the proposed rule for an analysis of the total costs of the two pathways to an ICD-11 implementation. One argument made against such an analysis is that the "the disruption and costs of transitioning to ICD-11 are highly unlikely to be less those of transitioning to ICD-10." I agree that each individual implementation may have comparable costs, but that does not compare the cost of the two pathways which are:
- Implement ICD-10, then implement ICD-11 (two complete implementations)
- Forego ICD-10 to implement ICD-11 (one implementation + sunken ICD-10 investments)
What is the comparable cost of each pathway? A comparison of the cost and benefits could have a significant impact on the decision. Let's learn from this for next time.
By the way, there will soon be a next time. I fear that this decision locks the U.S. into another cycle of the same-- using a diagnosis coding system that rapidly becomes archaic and leads to another decade of desperate efforts into the 2030s to upgrade after the rest of the world has already transitioned to ICD-11.
I also fear that that the burden will be excessive on healthcare organizations in 2014 to implement ICD-10 and meet the 2014 Stage 2 Meaningful Use requirements which were both announced by CMS this week. This burden will be greatest on the small, individual physician practices are already throttled by meaningful use, 5010, e-prescribing and healthcare reform. They are struggling to find the time and resources for the ICD-10 effort. Since the EHR Incentive Program has a specified timeline under ARRA, I believe this excessive burden is likely to trigger another delay of ICD-10, at least for small physician practices.
Will we be left wondering why we didn't just stop investing in ICD-10 back in 2012?