AHIMA: The time is now for ICD-10 conversion mitigation
CHICAGO--Updating to ICD-10-CM/PCS is a necessary step in realizing the anticipated benefits of health IT, according to Sue Bowman, director of coding policy and compliance at the American Health Information Management Association (AHIMA), who made a presentation Monday at the annual meeting of the Healthcare Information and Management Systems Society (HIMSS).

There are three ICD-10 code sets: ICD-10 is a diagnosis coding system developed by the World Health Organization (WHO) as a replacement to ICD-9, which was implemented for mortality coding in the United States in 1999. ICD-10-CM is the U.S. clinical modification of the WHO's ICD-10, but it has no procedure codes. The Centers for Medicare & Medicaid Services (CMS) developed ICD-10-PCS to replace the ICD-9-CM procedure coding system.

Bowman said that ICD-9-CM "badly needs to be replaced" for many reasons, including:
  • A 30-year-old system that is running out of space for codes;
  • Terminology and classification of some conditions are outdated and obsolete;
  • Unable to keep pace with advances in medical technology and meet current or future health data needs;
  • Outdated codes produce inaccurate and limited data;
  • Lack of international comparability; and
  • Cannot support transition to interoperable health data exchange.

According to the final regulation, published in the Federal Register on Jan. 16, ICD-10-CM will be used in all healthcare settings, and ICD-10-PCS will be used for facility reporting of hospital inpatient services. The Department of Health and Human Services (HHS) anticipates the estimated impact of ICD-10-CM/PCS transition costs on providers, suppliers, payors and software and system design firms is $1.88 million. However, HHS has estimated that the transition will cost $4.54 million over 15 years.

Bowman said that a "compliance date of Oct. 1, 2013 achieves a balance between the industry's need for a feasible amount of time for implementation and HHS' need to begin reaping the benefits of the new code sets, end the problems associated with continued use of ICD-9-CM, achieve global healthcare data compatibility, plan and budget for the transition appropriately and mitigate the cost of further delays."

She also noted that the implementation will have no impact on the use of CPT and HCPCS Level II Codes. These codes will continue to be used for reporting physician and other professional services and for procedures performed in hospital outpatient departments and other outpatient facilities.

The ICD-10-CM/PCS transition presents both challenges and opportunities, according to Bowman, highlighting the scope and complexity as integral factors. She also noted that coded data is more widely used than when the United States transitioned to ICD-9-CM.

"More sophisticated computer-assisted coding will revolutionize the coding process," especially through advances in mapping from clinical terminologies, Bowman said.

Specifically, she noted that implementation issues included impact on productivity and accuracy and data trending. First, productivity and accuracy complications are expected to be short term (about six months) "due to improved code set logic and design," Bowman said. For data trending challenges, maintenance of crosswalks among coding systems for longitudinal data analysis and the potential for faulty decisions due to distorted, inaccurate or misinterpreted data can present as problems.

General equivalence maps (GEMS) between ICD-9-CM and ICD-10-CM/PCS provide a link between code sets. However, Bowman said that "GEMS are not crosswalks; they are reference mappings to help the user navigate the complexity of translating meaning from one code set to the other."

She noted that bi-directional maps are available on the CMS and NCHS websites, and a reimbursement map was added to the CMS website this year. The reimbursement map is "intended for use by payors as a temporary mechanism to allow claims to be processed by legacy systems until internal systems have been fully converted." Bowman also stressed that "none of these maps should be used for coding medical records."

Bowman concluded that there will be consequences to inadequate preparation, include "huge coding backlogs, increased claims rejections and denials, increased delays in processing authorizations and reimbursement claims, improper claim payment, compliance issues and decisions will be based on faulty data.

"We hope through effective planning and implementation--starting now--many of these problems can be mitigated, and perhaps either minimized or even prevented," she concluded.