Health Information Management

Twists and turns on the road to ICD-10-CM/PCS implementation

JustCoding News: Outpatient, November 30, 2011

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On November 17, CMS’ Office of E-Health Standards and Services (OESS) announced it would delay enforcement of the HIPAA 5010 transaction standards until March 31, 2012.

Just two days prior, the AMA voted to do everything it could to stop implementation of ICD-10-CM/PCS.

What does that mean for your ICD-10-CM/PCS implementation plans?

Probably not much. The decision regarding enforcement has no impact on the compliance date for ICD-10-CM/PCS.

OESS decided to delay HIPAA 5010 enforcement when it determined that many covered entities continue to wait for software updates and would thus be unable to meet the implementation deadline. As such, covered entities are still required to implement HIPAA 5010 by January 1, 2012; however, they won’t face any enforcement actions until the end of March.

The AMA’s opposition to ICD-10-CM/PCS implementation probably won’t delay ICD-10-CM/PCS though. “CMS has been very firm about the date, so people should move forward with their implementation,” says Sue Bowman, RHIA, CCS, director of coding policy and compliance for the American Health Information Management Association (AHIMA) in Chicago.

“In my mind, it's important for [clinical documentation improvement staff members] to prepare the physicians for the present and the future,” adds Robert S. Gold, MD, CEO of DCBA, Inc., a consulting firm in Atlanta. If CMS does delay implementation, healthcare professionals will simply have more time to get a toehold in the thought processes. “If they don’t start now, they’re wasting time regardless.”

Rather than fear the unknown, coders should embrace the change to a more detailed code set, Gold says.

Reasons for the change

The United States will be the last industrialized country to implement ICD-10-CM/PCS, which puts it 10 years behind Canada and even further behind Europe. The world is becoming globalized, which makes information sharing more important, Bowman says.
U.S. healthcare providers can’t share data with other countries because of the different code systems. They also can’t compare disease rates.

Another significant reason for the switch to ICD-10-CM/PCS is that ICD-9-CM cannot expand to accommodate additional diagnoses and procedures. “Clearly, ICD-9 isn’t going to be able to hold up to the data demands we have in the 21st century, and it needs to be replaced,” Bowman says.

As a result, more and more out of sequence codes come into play each year. This creates confusion for coders because codes don’t follow a logical order. ICD-10-CM includes thousands of additional codes already, and it has plenty of room to expand in the future.

In addition, many ICD-9-CM codes lack detail, especially ICD-9-CM Volume 3 procedure codes.

Even many of the ICD-9-CM diagnosis codes are ambiguous and lack the detail of the ICD-10-CM codes, Bowman says.

For example, in ICD-9-CM Volume 3, coders can’t distinguish between a central venous catheter insertion and a peripherally-inserted central catheter. Both procedures map to the same code (38.93). In ICD-10-PCS, however, coders can report percutaneous placement of venous central line in right internal jugular (code 05HM33Z) as long as physician documentation supports code assignment.

The lack of detail in ICD-9-CM can result in misleading data, particularly data related to preventable infections or other adverse events, Bowman says. In some cases, adverse events are not preventable because of a patient’s underlying health problem or other factor. With ICD-10-CM/PCS, data regarding severity of illness, underlying conditions, and treatment will be more readily available. As a result, providers will be able to produce a better, clearer picture of the patients for whom it isn’t possible to prevent certain conditions, Bowman says.

Focus on quality measures

Part of the AMA’s rationale for opposing the switch to ICD-10-CM/PCS is that physicians and others are facing numerous other healthcare initiatives. However, many of these initiatives are data-driven, such as the Quality of Care measures, electronic medical record implementation, meaningful use, and payment reform. The central theme to each of these initiatives is data, so the switch to ICD-10-CM/PCS should actually help providers, Bowman says.

“You can’t benefit from any of it without good data,” Bowman says. “So if you do all of those things and then you are putting out data generated from an outdated, ambiguous coding system as the end result, you aren’t going to have any good data to be able to move forward on any of those initiatives or be able to evaluate the quality of carethe expected benefits of these initiatives won’t be realized, since high-quality data is at the core of improving the quality and efficiency of patient care.”

Instead of worrying about the transition, Gold recommends that providers look at how other countries implemented ICD-10-CM/PCS. “Repeating the mistakes of others through history is idiocy if you can learn from successes and mistakes of others and eliminate roadblocks,” he says.

E-mail your questions to Senior Managing Editor Michelle A. Leppert, CPC-A, at

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