The AMA(American Medical Association) has upped the stakes in the fight against ICD-10 recently writing a letter to Congress urging lawmakers to stop HIPAA’s required implementation of ICD-10 and to call on stakeholders to assess an appropriate replacement for ICD-9. AMA is stating that the implementation of ICD-10 will create no additional burdens on the practice of medicine and have no direct benefit to individual patient care, as physicians struggle with other costly transitions associating with implementing electronic health records in their practices.
AMA CEO and executive vice president, James L. Madera states, “the struggle to keep up with the various health IT use and reporting requirements leaves little time for physicians to get engaged in the practice redesign and payment and delivery reforms envisioned in the Affordable Care Act. Physicians will be forced to close their Medicare patient panel or limit the number of Medicare patients that they treat in order to minimize the aggregate financial and administrative blows to their practice due to the unfair penalty programs that are being and will be administered.”
Yesterday on his blog, prominent physician blogger and CIO at Beth Israel Deaconess Medical Center, John D. Halamka MD also provided his thoughts that the billions of dollars to implement ICD-10 will not improve quality, safety, or efficiency. John states, “I’ve spoken to many people at HHS, CMS and the White House about the need to rethink the ICD10 timeline, deferring it until after Meaningful Use Stage 3 which enables us to focus on improving our clinical documentation and adopt SNOMED-CT to capture structured signs and symptoms.”
Enclosed in the AMA letter to Congress was a table and timeline that illustrated the drastic volume of financial penalties associated with various federal programs that physicians will be facing simultaneously as shown below:
Medicare Physician Incentives and Penalties
Year | Deficit Reduction Sequester* | E-Prescribing | Health Information Technology | Physician Quality Reporting System, including Maintenance of Certification (MOC) Program | ICD-10 Implementation |
2009 | | 2% | | 2% | |
2010 | | 2% | | 2% | |
2011 | | 1% | $18K | 1% if no MOC; 1.5% if MOC | |
2012 | | 1%(-1%) | $12-18K | 0.5% if no MOC; 1.0% if MOC | |
2013 | (-2%) | 0.5% (-1.5%) | $8-15K | 0.5% if no MOC; 1.0% if MOC | |
2014 | (-2%) | (-2%) | $4-12K | 0.5% if no MOC; 1.0% if MOC | $100 to $50,000 penalty per HIPAA violation, depending on if it is knowing, willful & corrected |
2015 | (-2%) | | $2-8K (-1%) | (-1.5%) |
2016 | (-2%) | | $2-4K (-2%) | (-2%) |
2017 | (-2%) | | _. | (-2%) |
2018 | (-2%) | | | (-2%) |
AHIMA’s Viewpoint
AHIMA responded to AMA’s initial attack against the implementation of ICD-10 late last year expressing their disappointment with AMA stating adoption of a 21st system classification system will bring important benefits to patients, providers, and payers. AHIMA’s CEO Lynne Thomas Gordon stated, “We need to move our disease classification system towards international standards and also align it with the meaningful use incentive program as well as value based reimbursement.” (Modern Healthcare 11/17)
Gordon’s response does support the fact that the Affordable Care Act (ACA) includes financial savings associated with reduction in healthcare fraud and abuse, which is one of the key benefits of ICD-10. ICD-10 provides the more granularity of diagnosis and treatment information making it easier to detect potential healthcare fraud/abuse. The transition to ICD-10 will provide more robust codes that will help support electronic health record’s detailed requirements of information more accessible to support the move towards health information exchanges between healthcare organizations.
Conclusion
With only a dismal 9% of healthcare providers only halfway through ICD-10 according to a KLAS report last October, does the AMA make a valid point when it comes to all the competing priorities physicians and healthcare organizations are faced with at this time? So who is right in this debate? Should ICD-10 be delayed until Meaningful Use stage 3 or are we focused on the wrong thing and instead should focus on implementing an efficient reimbursement system instead? What do you think?
To view the letter in its entirety, please click here