Today, I exist in a world where the last 12 hours of my time has been filled with a lot of information. As is my usual custom, about 1/3 of it is actually job-related.
It started last night at about 12 Midnight as I was watching an early ’70’s B-movie off of my DVR (I’m not even going to share the title with you, as this is one field of interest of mine that I can’t even begin to explain to people based on it being rooted in insomnia). As the movie’s plot and soundtrack continued in my head prior to leaving my house this morning, I was packing to leave for a weekend wedding in central Illinois. This morning, I listened intently at an off-site meeting on RAC issues that gave me weeks of fodder for my Wednesday posts in this space. Next comes preparations for the Fi-Med RAC Summit this coming Monday and Tuesday, a business invitation that was just extended to me upon my arrival in the office, the work awaiting my hands currently occupying my desk (the true 99%, if ever it could be measured) and we finally work down to the fact that I’m hungry and that my chosen lunchtime remedy for this condition today is woefully inadequate.
And then there’s the ICD-10 delay…….
For those of you in health care that have been living on a beach without cell service for the last week, CMS has issued a proposed rule indicating a new compliance date for ICD-10 of October 1, 2014.
I had a plan for today’s post, B-movies, meetings, packing and summits not withstanding. My plan was to share with you the comments I am going to share with CMS regarding the proposed rule that I shall upload onto Regulations.gov. The comment period for this proposed rule is only 30 days, which is CMS’ way of stating that they’re sick of the crosstalk on this topic. Unfortunately, the proposed rule has yet to be uploaded onto the comment site and I am not about to use regular mail for submission. Until such time as the proposed rule is entered into the Federal Register, allow me to give you all a preview of coming attractions.
You all know my feelings with regard to ICD-10 as it pertains to ICD-11. If you do not, please review this recent post. We now have a compliance date for ICD-10 that, thanks to delays (caused mostly by entities such as commercial insurance carriers who threw lobbying dollars), will fall 22 years after its release by the World Health Organization. I ask the reader to also remember that work on the design of ICD-10 began in 1982, the year that America was riveted by the happenings of the Ewing family on Dallas between spins around town in their AMC Eagles.
Here’s one last number for everyone to chew on, and this one will take up quite a bit of my comments to CMS. The proposed final compliance date for ICD-10 falls only seven months prior to the scheduled release of ICD-11 (including a clinical modification) in May of 2015. Because I’ve been banging the ICD-11 gong to CMS since 2008, newcomers that are late to my party are now telling me that an American clinical modification can’t be ready until 2024 or 2030, so I feel I need to respond to the conjecture emanating from certain quarters of our industry in the only way I know how, given my formative years spent as a sports fan in the City of Philadelphia.
The only reason we have an American clinical modification to ICD at all is because we kowtow to the insurance industry so they can use the US version to more easily deny claims. ICD-11 is a system that brings SNOMED CT into the code set for better clinical representation of a patient’s condition. If we are truly concerned about paying for performance rather than quantity, and if we want to redefine the fundamental goal of medicine in the United States to be one of better patient outcomes, then who in their right mind would argue to putt along with a clunker of a reporting system for up to 16 more years?
If you were reading this post thoroughly, you know that the answer to that question is the companies of yesterday who threw money towards adopting ICD-10 as the reporting standard.
There was a time when people in other parts of the world were isolated from one another, which made one global disease and morphology reporting standard something of a moot point. We now live in a world of international interaction brought on by technological advances in travel and communication. For the rest of the world to utilize one reporting standard while the United States uses another is no longer a viable option. I feel happy to add that throwing out monetary reasons to justify being behind shows a distinct lack of citizenship. In America, if you want to get something done, you plan and act. Crying about all of the money you spent (or are about to spend) on ICD-10 is the same as telling me “but we’ve always done it this way” and you never says those words to a compliance officer.
My pending drive deep into Illinois, my workload, today’s meeting, next’s week’s Summit, my growling stomach and B-movie soundtracks and plot lines will continue on in my head unabated until I decide to bring new stimuli into it in order to continue evolving. I would recommend to those who wish to belittle the idea of a faster ICD-11 implementation to perhaps open their minds to the same process.