Unintended Consequences Of ICD-10 Delay

“I find it comical that credibility and date are in the same sentence,” Sid Hebert said, “since we’re going for our fourth” ICD-10 compliance deadline.

Hebert, Humana’s ICD-10 program manager, predicted that if the current delay goes out beyond one year, large payers will essentially “mothball” the project with the intention to reinstate ICD-10 work roughly 6 months ahead of whatever might be the new date.

“What will suffer is the testing,” Hebert said at WEDI’s emergency ICD-10 summit, convened in response to the Protecting Access to Medicare Act of 2014 that prohibits the Department of Health and Human Services from requiring ICD-10 prior to October 2015.

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Pushing off testing is only one of the unintended consequences that the law triggered by delaying ICD-10. Organizations now have to reassess the project and redefine their requirements, and many will have to find resources to do that, notably financial and personnel.

Take Geisinger Health Plan, for instance. The organization’s fiscal year 2015 budget, which is already baked, was plotted with the October 1, 2014 deadline in mind, according to Debra Cadwallader, Geisinger’s ICD-10 program manager.

“We don’t have a budget for ICD-10 in 2015,” Cadwallader said.

Yet, a common theme was that extending the deadline will cost healthcare organizations more than complying in 2014 would have, with one attendee estimating it could be as high as an order of magnitude more money.

Vendors also will absorb extra costs. Debbie Meisner, Emdeon’s vice president of regulatory strategy said that another aspect will be how to handle the ICD-9 codes, which were frozen in anticipation of ICD-10. At least some technology providers will have to maintain both ICD-9 and ICD-10 for another year.

“Those are two separate code sets we have to pay for,” Meisner said, “and they’re not cheap.”

And while that is being ironed out, Shelagh Kalland, director of ICD-10 program operations Blue Cross Blue Shield Minnesota, said that knowledge will be lost. “We get quality information out of claims data,” Kalland said. “Dual coding distorts that quality.”

Whether dual coding, as in operating under both ICD-9 and ICD-10 simultaneously, becomes a consequence of this latest delay or not remains to be seen, of course, at least until HHS issues a new deadline. Unless HHS changes the plan beyond just mandating a new date, dual coding will exist in a limited fashion.

This latest delay and the lack of a new deadline are also undercutting credibility, of both the federal government’s ICD-10 stance and the providers and payers charged with implementing the code sets, be those IT folks, CIOs or ICD-10 program managers.

“My biggest concern is that we create an environment of institutionalized apathy. Folks look at how they invest money, resources. Those that sat back, they look like winners today,” said Erik Newlin, director of national standards consulting at Xerox Healthcare and co-chair of WEDI’s ICD-10 assessment workgroup. “This kind of reinforces exactly that. The folks on the front-end have to ask why should I next time?”

That is a question many chief financial officers are likely asking this month. And while the concept of mothballing the conversion until approximately six months before the new deadline is not ideal, Humana’s Hebert said, the reality that decisions come from the top down may dictate that approach whether it makes sense or not.

“Our senior leadership is becoming extremely wary of financing ICD-10,” Humana’s Hebert said.

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