Organized medicine urges CMS to halt ICD-10 switch

Washington The mandated transition in late 2014 to new diagnosis codes used for billing medical services will be a significant burden for physician practices and cause many to go out of business, the American Medical Association and scores of other organized medicine groups stated in a Dec. 20, 2012, letter.

The administrative and financial strains of switching to the ICD-10 code set will come at a time when physicians also will be required to participate in several quality and health information technology programs. Overlapping federal regulations and the continued threat of steep Medicare physician pay cuts will make the transition extremely difficult, the AMA and about 80 specialty and state physician organizations wrote in the letter to acting Centers for Medicare & Medicaid Services Administrator Marilyn Tavenner.

“Stopping the implementation of ICD-10 is a critical, necessary step for removing regulatory burdens on physicians and ensuring that small physician practices are able to keep their doors open,” the letter stated.

In November 2012, the AMA House of Delegates approved official policy to advocate for the elimination of mandated ICD-10 implementation and reiterate to CMS, which is overseeing the transition, that the burdens imposed by ICD-10 on physicians will force many out of business.

Responding to past pressure from organized medicine, the Obama administration in August 2012 finalized rules to delay the rollout of ICD-10 by one year to Oct. 1, 2014. The AMA and other organizations appreciated the extra time, but the eventual required transition to new diagnosis codes still represents too much of a hardship — especially for small practices, they said.

Public health officials and other proponents have said the switch to the new code sets is long overdue. The current ICD-9 standard was established 30 years ago, while the alphanumeric ICD-10 set accomplishes the same job but offers much more specificity about services and claims efficiency. For instance, ICD-10 could decrease the need to include supporting documentation with claims for services, according to an American Hospital Assn. website about some of the benefits of the upgrade.

ICD-10 has about 68,000 codes, a fivefold increase from ICD-9’s roughly 13,000 codes, the organized medicine letter states. ICD-10 is more nuanced and detailed, requiring administrative and financial resources to ensure the correct codes capture a patient’s problems for billing and other purposes. Internal billing systems, for example, will require upgrades, and staff will need training to familiarize themselves with the codes.

“Physicians will be responsible for all of these costs, which, depending on the size of a medical practice, will range from $83,290 to more than $2.7 million,” the letter stated.

The timing of the transition puts it into play at a particularly difficult time for physicians, the letter stated. Practices are allocating resources to participate in Medicare-led quality programs, such as the physician quality reporting system, and taking steps to adopt electronic health records. If physicians do not report quality measures or use EHRs, they will pay an additional price through penalties that will take effect beginning in 2015.

“We do not support the financial penalties associated with these programs,” the groups said. “Moreover, the compounding effect of these potential penalties is made worse by the up to two-year lag time between the periods for measuring performance and applying penalties — making it impossible for physicians to learn about and correct errors and avoid penalties before ICD-10 implementation begins.”

The AMA has urged CMS to align timelines and requirements for these programs to minimize burdens on physicians. Stopping the mandated ICD-10 upgrade, while assessing what eventually should replace ICD-9, “will help keep adoption of EHRs and physician participation in delivery and payment reform models on track,” the letter stated.