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CMS prematurely dismisses the alternative option to forgo ICD-10 and implement ICD-11

In their proposed rule to delay ICD-10, CMS prematurely dismisses (in three short sentences) the alternative option to forgo ICD-10 completely and implement ICD-11 instead.    I am 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. 

In a recent Health Affairs report  the authors express concerns that adopting ICD-10 for reimbursement will be disruptive and costly with little material improvement over the current system.  These informatics experts fall short of suggesting we forgo ICD-10 for ICD-11, but they do recommend that policymakers begin planning now to facilitate a tolerable transition to ICD-11.   We should recognize that this article was not an appropriate platform for the authors to make a political statement to forgo ICD-10.   In addition, more information is needed before making such a recommendation:

  1. What is the earliest date by which the U.S. could implement ICD-11?  CMS suggests that it could be as early as 2020-2022.  What could be done to possibly accelerate that date?
  2. What is the earliest date we could implement ICD-11 if we implement ICD-10 first?  Historical data suggests 2028 is the earliest, but some informatics experts suggest it will be after 2030.
  3. What is the estimated total cost to complete the ICD-10 implementation, then convert to ICD-11?
  4. What is the total cost of stopping the ICD-10 implementation today and proceeding with ICD-11, including the sunken costs of work already done on ICD-10?
  5. What value will ICD-11 provide over ICD-10?
  6. How does the total cost to the industry for using ICD-9 codes another 5-7 years (while ICD-11 is implemented) compare to the total cost to the industry for using ICD-10 codes instead of ICD-11 for 13 or more years after ICD-10 is implemented?
  7. What additional burden will be imposed on physicians and small hospitals by requiring two code system conversions over the next 15 years?  What are the capital costs physicians and small hospitals will incur under both pathways? 
  8. What other potential impacts could there be on physicians and small hospitals?   Will it drive an increasing number of physicians into early retirement?   Will some small hospitals be forced to close?   Will it drive a decision by increasing number of physicians to convert to a concierge or cash-only practices?  

These and other potential impacts have not been fully assessed by CMS.   Implementing ICD-10 has been compared to buying a Betamax instead of a VHS recorder in terms of pending obsolescence.   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.   Perhaps the optimal pathway to ICD-11 really is through the ICD-10, but we need a more comprehensive analysis to make a better-informed decision.   Let’s put on the table the total costs and impact of both pathways and then decide.

You may read here my entire public comment as submitted to CMS on the proposed rule to delay ICD-10 for one year.


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Dr. Murray, just letting you know that the AMA has now taken up the cause of investigating other options to the ICD-9 replacement, ICD-11 chief among those. I wrote about it right here and quoted from your May 17 post.
Tom Sullivan
Editor, Government Health IT

Tom, thanks for the fair and accurate use of quotes from my blog. Your prediction that ICD-10 will ultimately be implemented with strong support from AHIMA and ICD-10 profiteers is a solid one. I remain hopeful that CMS will engage in a national dialogue based on more comprehensive cost-benefit analyses to enable a better-informed decision on the optimal pathway to ICD-11. The AMA announcement, if nothing else, gives more credence to the need for such analyses!

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