Attorneys
Authored by Christopher J. Shaughnessy
Technical, health care-related system changes are a huge burden. Just ask the Obama Administration. The Affordable Care Act has taught us that industry-wide overhauls are difficult and time-consuming. Change can be hard, and costly, but sometimes it is necessary for the greater good. Such is the case with ICD-10 coding. Physicians may doubt the benefits of an upgraded coding system. Can improved patient care and better public health really be accomplished with different data entry?
The answer is yes. And, regardless of whether physicians agree or not, they must still jump on the ICD-10 bandwagon if they are a HIPAA covered entity (as must payers and clearinghouses). Luckily, in September 2012, the Department of Health and Human Services pushed the compliance date back to October 1, 2014. While this deadline is months away, there is much to be done now for a successful transition.
Background
To really understand the need for a new coding system, physicians must see the bigger picture and understand the history behind the codes. In the mid-1800's, European doctors and statisticians sought to develop uniform, international classifications for causes of death to be used in death certificates and from that initiative the first draft of the code system was born.[1]
Today, the International Classification of Diseases (ICD) is the standard diagnostic tool for epidemiology, health management and clinical purposes. It is used to monitor the incidence and prevalence of diseases and other health problems; classify diseases and other health problems recorded on many types of health and vital records including death certificates; and, provide the basis for the compilation of national mortality and morbidity statistics by WHO Member States. In addition, these codes help governments and private health insurers assess a value for each patient visit and determine how billions in health care costs should be allocated.
For decades, the American health care system has relied on ICD-9-CM's three volume set of codes. ICD-9 volumes 1 and 2 contain reporting codes for diagnoses and symptoms. Volume 3 contains codes for reporting hospital inpatient procedures. In October, the ICD-10-CM will replace ICD-9-CM volumes 1 and 2 and ICD-10-PCS ("Procedure Coding System") will replace ICD-9-CM volume 3. ICD-10 is not completely new to all health care entities. It has been used in American hospitals since 1999 to report hospital inpatient causes of death.
The limited use of ICD-10 within our health system is idiosyncratic when compared with the rest of the developed world. ICD-10 received WHO's endorsement over twenty years ago, in 1990.[2] Many countries have long past adopted the version. The United Kingdom, for example, adopted it in 1995.
The Differences
The ICD-9 manual, with its mere 13,000 codes, pales in comparison to its newer counterpart. With 68,000 codes, the ICD-10 is focused on exhaustive specificity. Is a patient's injury the result of being sucked into a jet engine? There's a code for that. Did a patient's hair cause external constriction? There's a code for that, too. The ICD-9 codes are mostly numeric with 3-5 digits, whereas the ICD-10 codes are alphanumeric with 3-7 characters.
In addition to the far-fetched injury scenarios and its new look, ICD-10 can differentiate between the left and right sides of the body and categorize a patient's encounter with an entity as an initial or subsequent visit.
The Opportunities
Even critics of ICD-10 can agree that ICD-9 has run its course. It is full of outdated and obsolete terms. Advanced medical technology has resulted in new procedures and assessments, but the structure of the current coding severely limits how these can be input. Coding chapters are divided according to body systems. Many of the complex body systems are have reached their code limit so that no new codes can be listed in these chapters. Coders have tried to account for new codes in other chapters to accurately reflect advances, but the result is a piecemeal set.
The increased precision has the potential to advance the quality of care that patients receive. Physicians will be able to better track a patient's improvements or setbacks. Having thorough historical data regarding diagnosis and treatment can lead to improved future treatment, along with reducing the patient costs associated with that treatment.
There is massive room for research improvement. The lag in technology has made it extremely difficult for researchers to compare data with other countries in recent years. The U.S. will now be able to better respond to requests for information from the WHO and track worldwide health trends and concerns.
Providers will be better able to compare performance and outcomes with their peers. The finer details can help physicians understand and improve upon current methods and procedures. Perhaps one of the biggest advantages providers can expect to see is increased efficiency with payors. ICD-9 codes were implemented before prospective payment systems existed. Once Medicare begin relying heavily on ICD codes for reimbursement purposes, choosing the right code became critical. As providers well know, additional documentation is almost always required to support claims and coding errors are easy to make. With ICD-10, the specificity will enable payors to better understand submissions, resulting in reduced paperwork and fewer rejected claims. More effective detection and investigation of potential fraud or abuse will also be a positive outcome.
Takeaway
Covered entities cannot begin using ICD-10 before October 14, 2014 (and few would be prepared to do so). Until September 30, 2014, ICD-9 codes must continue to be used. For care occurring on or after October 14th, only ICD-10 codes will be HIPAA-compliant. Just as we waited with bated breath on October 1, 2013, to see the healthcare exchange roll-out, so, too, will we wait to see how covered entities handle the revamp of coding.
ICD-10 is more than just another government regulation. It is more than an IT system upgrade. It will impact everyone in the industry. It will change manual processes in practice, policy and procedures, the way we think about patient care, and hopefully the way it is delivered. They say the devil is in the details...and there is a lot of detail with ICD-10, but physicians have to be committed to seeing the good in it.
Christopher J. Shaughnessy is a member at McBrayer law. Mr. Shaughnessy concentrates his practice area in healthcare law and is located in the firm's Lexington office. He can be reached at cshaughnessy@mcbrayerfirm.com or at (859) 231-8780, ext. 1251.
[1] World Health Organization, History of the development of the ICD, http://www.who.int/classifications/icd/en/HistoryOfICD.pdf (last visited March 7, 2014).
[2] Id.
