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AMA Seeks Reversal of ICD-10 Implementation Mandate from CMS

February 26, 2014:

Nichole VanHorn, Clinical/Technical Editor

A report it received in early February gives the American Medical Association new ammunition in its ongoing fight against the implementation of ICD-10, slated for this coming fall. The AMA summarized its arguments in a letter to Kathleen Sebelius, secretary of the Department of Health and Human Services, requesting that the ICD-10 mandate forcing the implementation be reversed.

On February 12, 2014, Nachimson Advisors delivered a report to the AMA detailing costs to physicians associated with the ICD-10 implementation. The report found that small practices can expect to spend anywhere from $56,639 to $226,105 to make the transition to I-10—a significant increase over 2008 estimates of $83,290, while large practice expense figures range from between $2 million to $8 million. The new estimates factor in costs associated with purchasing new software to accommodate the new codes as well as training, productivity loss, and payment disruptions that may occur while implementing the new system. The report acknowledges that implementation of ICD-10 has its advantages, such as greater clinical detail and specificity and updated terminology and disease classification. The main disadvantage the organization cites is cost, essentially creating an unfunded mandate for practicing physicians.

A few of the issues the AMA letter notes are:

  • The magnitude of implementation, involving an increase in diagnosis codes from 13,000 to 68,000
  • Unprecedented use of ICD-10 codes for determining reimbursement
  • Unlikelihood of ICD-10 codes to improve patient care
  • Possible interruption in ability to transition to other new delivery models
  • Possible hindrance of physician progress to a performance-based environment
  • Significant implementation costs since the Meaningful Use Program was enacted, as earlier cost estimates did not factor in certified electronic health record (EHR) software upgrades

The AMA’s letter to HHS compares the implementation of ICD-10 to the 2008 process used to implement the Health Insurance Portability and Accountability Act (HIPAA) mandate for a national provider identifier (NPI), which resulted in significant cash flow interruptions for physicians.

Note that while the AMA is seeking a reversal to the implementation, ICD-10 remains a federal mandate and physicians are urged to continue preparations for the October 1, 2014 deadline.


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