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ICD-10 Neutrality: How will you use your deadline extension?

Since Health and Human Services Secretary Kathleen G. Sebelius announced that HHS will initiate a process to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10), the healthcare industry is still trying to figure out the scope and the impact of the extension.

The statement did not offer more information about which “certain healthcare entities” would receive an extension, though HHS Secretary Kathleen Sebelius has suggested, “We have heard from many in the provider community who have concerns about the administrative burdens they face in the years ahead.  We are committing to work with the provider community to reexamine the pace at which HHS and the nation implement these important improvements to our health care system.”

What we do expect is that payers and providers alike have an opportunity to refine their approach for testing Payment, Benefit, Clinical, Operational and Financial Neutrality.  A few key questions that could be evaluated sooner rather than later may include:

  1. How will payers and providers sync up on GEMs?
  2. How will business departments evolve processes that use ICD-9 codes without payers and providers syncing up on GEMs?
  3. How will IT departments change the application logic of legacy systems that use ICD-9 codes if business can’t commit to evolving processes that use ICD-9 codes without payers and providers syncing up on GEMs?
  4. How will payers and providers recontract for an ICD-10 world if IT departments, well, you get the picture…

And, we now get to ask the new question, “if we expect the final version of ICD-11 in the 2015 timeframe, and we’re pushing out the ICD-10 deadline from October, 2013, then why don’t we just leapfrog ICD10 altogether?”  The answer is that we need to stay the course in the buildout of methods, approaches and processes for Neutrality Testing.

I did have an opportunity to assist a Canadian Provincial health organization in consolidating its internal governance that supported 34 health districts all within a province.  The intent behind the streamlined governance effort was to reduce the administrative overhead for administering care to allow a refocus of investment on the delivery of care.  Sound familiar?  This effort was initiated in 1997.  15 years later, this same Provincial health organization has 13 health districts.  It’s a work in progress…

Payer and Provider organizations do not always have alignment of internal business and IT.  Payers and Providers are not always in agreement with each other’s medical policy that will be used to defend a GEM.  Payers and Providers are not always in agreement with each other’s perspective of benefit and reimbursement.  Now let’s scale up from 17,000 ICD-9 codes to 155,000 ICD-10 codes…

What if the industry had access to an objective, 3rd party environment for the build out of joint medical policy and GEM development, based upon collaborative assessment of code variability risk?  Probably makes sense to focus on clinical equivalency before jumping to benefit and reimbursement, right?

What if the industry had access to an objective, 3rd party environment for the build out of joint process development for managing code variability risk as an ongoing process, and IT systems (or business rules/application logic) remediation was ongoing, and payer/provider was recontracting ongoing?

If we can learn to operationalize “change” maybe ICD-11 won’t be so bad.  Stay tuned…

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One thought on “ICD-10 Neutrality: How will you use your deadline extension?

  1. Steve Sisko

    Mike

    I’d be interested to hear more about what you believe an “objective, 3rd party environment” for payer-provider collaboration would look like. What would be some key features? Who would host it? How would it be funded? What would its governance structure look like? And more questions…

    You’re right to say it “makes sense to focus on clinical equivalency before jumping to benefit and reimbursement.” “Clinical” is the primary focus and always the end goal; but then that pesky coverage and reimbursement aspect always gets in the way. :’)

    One suggestion I have for this environment/platform/tool you proffer is that it should architect in – or at least consider positioning for handling of semantic relationships and meaning required by ICD-11. This is noted in today’s post on ICD-10 Watch: http://www.icd10watch.com/blog/converting-icd-11-codes-will-be-a-matter-semantics

    And was previously discussed by one of your compadres in a blog post titled “Semantic Web Technologies for ICD-9 to ICD-10 Conversion” See here: http://blogs.perficient.com/healthcare/blog/2011/10/13/semantic-web-technologies-foricd-10-conversion/

    Perhaps Perficient should start working on the requirements and solution architecture for such a platform and offer it up to the industry? :’)

    Steve S.

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