As I mentioned, practices cannot achieve ICD-10 success on their own. They must rely on their PM and EHR vendors for the necessary software and their clearinghouse and health plans to test. Clearinghouses were instrumental in facilitating practice implementation of HIPAA 5010 as they offered the service of converting a 4010 transaction to the new 5010. However, with ICD-10, clearinghouses have much less ability to assist practices. First of all, some 20 percent of practices are still on the 4010 version of the claim, and that version does not accommodate ICD-10 codes. Also, we do not believe that clearinghouses will be able to convert an ICD-9 code to ICD-10 on their own as that would require access to the full clinical documentation.

Further, the cost of adopting this new code set will be itself daunting. Only about a third of our research respondents indicated that their vendor would cover the cost of the PM and EHR software upgrade/replacement. For the average 10-physician practice that must cover the expense of these upgrades/replacements themselves, the research indicates that the cost will be $201,690. Add to this the expense associated with project management efforts, code selection software, superbill redesign, staff training, and the reworking and resubmitting of denied claims. Compounding the angst of this transition, there is the unknown impact of decreased coder and clinician productivity following the compliance date.


DMN: Why do you think readiness has been slow?
ST: There are a number of factors contributing to a slowed implementation of ICD-10. Trading partners such as vendors, clearinghouses and health plans have been focused on numerous other federal and private sector initiatives, including Stage 1 and 2 of the Meaningful Use EHR Incentive Program, the Affordable care Act-mandated administrative simplification requirements, such as operating rules, national health plan identifier and the electronic funds transfer transaction, and health insurance exchanges.

Uncertainty undoubtedly also plays a role. ICD-10 is perhaps the only HIPAA standard that many physicians have actively opposed. We assert that the government has not taken the critical steps necessary to build the case for adoption — steps such as completion of an accurate ROI assessment, identification of the pre- and post-implementation costs for practices, and the undertaking of a comprehensive pilot.

In addition, there is currently legislation in both the House and Senate calling for the repeal of ICD-10 — further indication that key constituencies have not been persuaded that the process of implementing ICD-10 adopted by CMS is appropriate. In our industry, uncertainty, coupled with multiple competing priorities, can lead to inaction.

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