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May 2013

AMA Fails To Do Homework on ICD-11 Cost Analysis

The American Medical Association (AMA) failed to complete their homework assignment before concluding in a report that skipping ICD-10 to move directly to ICD-11 is not a feasible option. Just like CMS (see CMS prematurely dismisses the alternative option to forgo ICD-10 and implement ICD-11), the AMA failed to compare the total cost of implementing ICD-10 and then implementing ICD-11 to the total cost of foregoing ICD-10 to implement ICD-11 sooner. To make matters worse, the AMA's report openly states that they only performed a preliminary assessment of the feasibility of moving from ICD-9 directly to ICD-11.   Since when does one draw a final conclusion based on a preliminary assessment?  

Several statements in the report lead me to believe that the AMA prematurely issued this report without performing a comprehensive analysis in order to maintain political relationships with other healthcare stakeholders.    For example, the AMA states that "while many physicians have concerns about the costs and burden of ICD-10, there are many other stakeholders, including 24 government agencies, researchers, large payers, large health system providers, and public health entities, that support the conversion."    OK, let's think about that...the AMA acknowledges that physicians are concerned about the costs, and yet they offer no comparative analysis of the costs. Which relationships have the appearance of being more important to the AMA in this case:  physicians or others?

The AMA states that "stakeholders have already invested millions towards the adoption of ICD-10."   This is certainly true, but I do not see these sunken costs as an obvious reason to eliminate the ICD-11 option. Instead, I see these costs as one of the important variables in a simple equation:

x= total cost of ICD-10 implementation + total cost of ICD-11 (two complete implementations)

y=sunken cost of ICD-10 work + total cost of ICD-11 (one complete implementation + sunken cost of partial implementation)

Is x greater than or less than y?   As a physician I expect my professional organization to actually do the math before writing down an answer.  

And finally, the AMA makes an argument for ICD-10 because "some have speculated" that it could take 20 years to implement ICD-11.   This is really quite embarrassing, as even CMS stated in their  ICD-10 final rule that ICD-11 could be implemented as early as 2020.   In a recent  Health Affairs report informatics experts speculate that an accelerated ICD-11 implementation could occur in 5-7 years, and they are in agreement that we need to transition to ICD-11 sooner than 20 years from now.

I recognize AMA as a strong advocate for physicians, but I give the organization an "F" on this homework assignment.