Wednesday, November 16, 2011

Response to American Medical Association’s Opposition to ICD-10 Implementation

On November 15, 2011, the American Medical Association’s (AMA) House of Delegates voted to vigorously stop the implementation of ICD-10.

AMA president, Peter W. Carmel said, "The implementation of ICD-10 will create significant burdens on the practice of medicine with no direct benefit to individual patients' care. At a time when we are working to get the best value possible for our health care dollar, this massive and expensive undertaking will add administrative expense and create unnecessary workflow disruptions. The timing could not be worse as many physicians are working to implement electronic health records into their practices. We will continue working to help physicians keep their focus where it should be – on their patients."

While we agree the transition to ICD-10 codes will be a major undertaking and result in added costs up front, our stance is that ICD-10 transition is both beneficial to the healthcare arena and long awaited. AMA stance that they are opposing this so physicians can keep their focus on the patients is not justified. While physicians have to document diagnoses for each patient encounter, this ultimately would not change the physicians focus on their patients.  They rarely are responsible for the final submission of codes prior to billing. This should be the responsibility of certified medical coders to ensure accuracy.

Several studies have been conducted weighing the costs and benefits of ICD-10 conversion. A study sponsored by the National Committee on Vital and Health Statistics (NCVHS) and conducted by the RAND Corporation evaluated the cost of training, productivity loss and system changes versus the benefits of going to a “superior code” set[1]. It concluded that the benefits outweighed the costs associated. Benefits included those to providers such as more accurate payment and fewer rejected claims, as well as patient benefits including improved disease management and timelier intervention of emergent diseases, such as SARS, which cost the Asian economy more than $10 billion.

Additional reasons why transition to ICD-10 is crucial include:
·    Endorsed by the World Health Organization (WHO) all the way back in 1993, ICD-10 is currently used in all other industrial countries around the world. With all countries on the same system, the WHO and Center for Disease Control (CDC) can have more accurate and consistent health records which are critical to ensure the quality of care, sound management, health financing and administration of health systems.
·    Since the implementation of ICD-9 in 1979, many new diseases and diagnoses have been discovered. The current ICD-9 system of three-digit categories and no more than 10 subcategories can no longer accurately track why people seek medical treatment.

We urge the AMA to direct its attention to other pressing issues in the healthcare arena, and focus on solutions. One such issue is the current law that prohibits nurse practitioners and other advance practice providers from ordering and managing patients under home care.  There are currently bills in Congress (H.R. 2267) and Senate (S. 227) to amend this law, recognizing the shortage of primary care physicians and an aging population in need of chronic care. There have been other bills introduced in the 111th Congress.  Both these bills died because they were not addressed before the end of session. The AMA has historically slowed progress of expanding the roles of nurse practitioners on both state and federal levels by consistently requesting additional studies and discussions on various NP issues.  Even when there is clear evidence based data showing expansion of the advanced practice nurse roles have significant cost benefits while delivering safe patient care. A recent study by Dobson, DaVanzo & Associates shows the cost savings over 10 years to be $309.5 million dollars to the Medicare system by using nurse practitioners to order and manage home care patients.[2] AMA’s official support of this overdue legislation would help facilitate getting these bills pushed through Congress and the Senate.

The second issue in need of the AMA’s attention is opposing Medicare Advisory Commission’s (MedPAC) recommendations to add copays to Medicare home care episodes.  Medicare home care service copays has been advanced in Congress as a means of deficit reduction as well as a means of limiting the growth of Medicare home health expenditures. Some Medicare Advantage (MA) plans have imposed home health copays. Copays are regressive, in-efficient and fall most heavily on the poorest and oldest Medicare beneficiaries.

The National Commission on Fiscal Responsibility and Reform (2010) recommended a uniform 20 percent copay and a uniform overall deductible of $550 for all Medicare services combined, including home health care. In January 2011 the MedPAC voted to recommend a home health copay (as much as $150 per episode) for episodes not preceded by a hospital or nursing home stay as a means to encourage beneficiaries to control utilization of care. Once again, the AMA’s strong opposition to these recommendations would have a larger impact on patient’s receiving care through proper healthcare access.

It is well accepted that ICD-10 will allow for quicker and larger medical care advancements. While the AMA may try to stop or delay ICD-10, we strongly believe it will and should be implemented. Health and Human Services (HHS) has already delayed implementation by two years to give institutions and providers additional time to prepare for this transition. We see a low probability, as well as little benefit, of it being delayed any further. AMA's opposition of ICD-10's implementation will only further delay the American healthcare industry from keeping up with the rest of the world.



[1] http://www.rand.org/pubs/technical_reports/2004/RAND_TR132.pdf

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