ICD-10 Postponement Opens the Door to ICD-11?

With CMS confirming that they are considering a delay in the final mandate for ICD-10 past the October 1, 2013 current deadline,  there are some discussions going on about skipping it entirely in favor of ICD-11.

Some things about ICD-11 – The base version from WHO is expected in May 2015.  After that, the United States will probably need another two years for development of the US version.  The earliest it would be available for study would be 2017, and we would need another 4 years to implement it – so that brings us out to 2021, way too far in the future.

Second and most importantly, we do not favor penalizing the companies that have started work on time on ICD-10.  The health care industry has spent hundreds of $millions already on ICD-10 education, assessments, etc.  Some hospital organizations are not happy about the delay, either.

It would be best for health plans, hospitals, and physicians to use the extra time to implement ICD-10 correctly.  There are consortiums that have sprung up to help with this effort.  We’ll be discussing this more at HIMSS 12 this week in Las Vegas, NV.

Discussion has been that ICD-10 is a steppingstone to ICD-11, so it is probably a good thing to do.  Also, ICD-9 has about had it, so we can’t see keeping it around another 10 years.  Note that ICD-10 procedure codes have nothing to do with the diagnosis codes or ICD-11, so that is a non- factor.  The ICD-10 procedure codes for use in hospitals are a significant improvement.

The theory of a staggered start to ICD-10 has also been floated – that CMS might continue to mandate the October 1, 2013 date for some plans or providers while offering relief to others.  One theory is that smaller entities or rural providers might get relief.   This seems equitable – that those who have invested in ICD-10 and can afford to meet the ICD-10 date would continue on their current path, while those who cannot afford it get a break.  However if one considers the national impact of a staggered start, it means that payors would have more dual processing of ICD-9 and ICD-10 claims to consider, based on a new factor – size of the provider and perhaps their location.  Would this relief really help or cause more havoc?  We’ll all learn more when CMS clarifies their statement that “certain entities” might be impacted.

There are clear benefits in our mind of ICD-11, including SNOMED CT clinical vocabulary supporting Electronic Medical Records.  However, the ICD-10 train has left the station.  It should be arriving – just later than scheduled.

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Michael F. Arrigo

Michael Arrigo, an expert witness, and healthcare executive, brings four decades of experience in the software, financial services, and healthcare industries. In 2000, Mr. Arrigo founded No World Borders, a healthcare data, regulations, and economics firm with clients in the pharmaceutical, medical device, hospital, surgical center, physician group, diagnostic imaging, genetic testing, health I.T., and health insurance markets. His expertise spans the federal health programs Medicare and Medicaid and private insurance. He advises Medicare Advantage Organizations that provide health insurance under Part C of the Medicare Act. Mr. Arrigo serves as an expert witness regarding medical coding and billing, fraud damages, and electronic health record software for the U.S. Department of Justice. He has valued well over $1 billion in medical billings in personal injury liens, malpractice, and insurance fraud cases. The U.S. Court of Appeals considered Mr. Arrigo's opinion regarding loss amounts, vacating, and remanding sentencing in a fraud case. Mr. Arrigo provides expertise in the Medicare Secondary Payer Act, Medicare LCDs, anti-trust litigation, medical intellectual property and trade secrets, HIPAA privacy, health care electronic claim data Standards, physician compensation, Anti-Kickback Statute, Stark law, the Affordable Care Act, False Claims Act, and the ARRA HITECH Act. Arrigo advises investors on merger and acquisition (M&A) diligence in the healthcare industry on transactions cumulatively valued at over $1 billion. Mr. Arrigo spent over ten years in Silicon Valley software firms in roles from Product Manager to CEO. He was product manager for a leading-edge database technology joint venture that became commercialized as Microsoft SQL Server, Vice President of Marketing for a software company when it grew from under $2 million in revenue to a $50 million acquisition by a company now merged into Cincom Systems, hired by private equity investors to serve as Vice President of Marketing for a secure email software company until its acquisition and multi $million investor exit by a company now merged into Axway Software S.A. (Euronext: AXW.PA), and CEO of one of the first cloud-based billing software companies, licensing its technology to Citrix Systems (NASDAQ: CTXS). Later, before entering the healthcare industry, he joined Fortune 500 company Fidelity National Financial (NYSE: FNF) as a Vice President, overseeing eCommerce solutions for the mortgage banking industry. While serving as a Vice President at Fortune 500 company First American Financial (NYSE: FAF), he oversaw eCommerce and regulatory compliance technology initiatives for the top ten mortgage banks and led the Sarbanes Oxley Act Section 302 internal controls I.T. audit for the company, supporting Section 404 of the Sarbanes Oxley Act. Mr. Arrigo earned his Bachelor of Science in Business Administration from the University of Southern California. Before that, he studied computer science, statistics, and economics at the University of California, Irvine. His post-graduate studies include biomedical ethics at Harvard Medical School, biomedical informatics at Stanford Medical School, blockchain and crypto-economics at the Massachusetts Institute of Technology, and training as a Certified Professional Medical Auditor (CPMA). Mr. Arrigo is qualified to serve as a director due to his experience in healthcare data, regulations, and economics, his leadership roles in software and financial services public companies, and his healthcare M&A diligence and public company regulatory experience. Mr. Arrigo is quoted in The Wall Street Journal, Fortune Magazine, Kaiser Health News, Consumer Affairs, National Public Radio (NPR), NBC News Houston, USA Today / Milwaukee Journal Sentinel, Medical Economics, Capitol ForumThe Daily Beast, the Lund Report, Inside Higher Ed, New England Psychologist, and other press and media outlets. He authored a peer-reviewed article regarding clinical documentation quality to support accurate medical coding, billing, and good patient care, published by Healthcare Financial Management Association (HFMA) and published in Healthcare I.T. News. Mr. Arrigo serves as a member of the board of directors of a publicly traded company in the healthcare and data analytics industry, where his duties include: member, audit committee; chair, compensation committee; member, special committee.

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