On June 13, mere days before Mostashari made that remark Monday at the HIMSS Media ICD-10 Forum in National Harbor, Md., the Medical Group Management Association (MGMA) disclosed that fewer than 5% of physician groups had made significant progress on ICD-10 and that 55% of practices hadn't yet started to implement it. The American Health Information Management Association (AHIMA) recently reported that more than half of hospitals were still in the initial phase of ICD-10 implementation last fall.
So are there any circumstances under which the Centers for Medicare and Medicaid Services (CMS), which is administering the transition, might blink?
Edward Hock, a director of the Advisory Board Co., a Washington, D.C.-based consulting firm, doesn't think so. And he believes that by the end of this year, far more healthcare organizations will be engaged in preparing for ICD-10.
"We're seeing more and more organizations tackle this more seriously than at any point yet," Hock told InformationWeek Healthcare. "And that increased attention will accelerate between now and the end of the year, as well as between now and the transition."
Hospitals still have a lot to do, he noted, but they've been engaged in this far longer than physicians have because their migration to ICD-10 will be far more complex.
"There's a lot that physician practices need to be concerned about," he said. "But if they turn to ICD-10 pretty seriously over the next six months -- which we're beginning to see happen -- they can be well set up for success prior to the transition."
Payers, vendors and clearinghouses all have important roles, but Hock said that providers need to take the first steps "to know who they need to test with and what updates they expect to receive."
He believes that providers, after much hemming and hawing, are finally beginning to pay attention. "You're hearing less talk about potential delays. AMA [American Medical Association] and MGMA have not spoken as seriously about the possibility of delay as they did last year."
When a significant fraction of providers were not ready to use the 5010 transaction set by the deadline of Jan. 1, 2012, CMS adopted a contingency plan: It announced that the deadline would stay in place, but that legal enforcement of the 5010 requirement would not take place until six months later.
Hock said he was unaware if CMS had a similar contingency plan in place for ICD-10. While the agency is unlikely to allow a train wreck, he said, "There's nothing that would lead organizations to believe they should not be prepared to the fullest for ICD-10 by October 2014."
In any case, he added, organizations that were unprepared for the 5010 transaction set later regretted it. "Providers who had a rough transition [to 5010] experienced increased days in [accounts receivable] and billing nightmares they'd rather have avoided."
Meanwhile, Mostashari pointed out at the HIMSS Media ICD-10 Forum, his office has tried to reduce the burden of ICD-10 by commissioning the National Library of Medicine to create a "crosswalk" between ICD-10 and the SNOMED nomenclature that EHRs certified for Meaningful Use Stage 2 must incorporate. This crosswalk would allow EHRs to generate ICD-10 codes automatically from the documentation in SNOMED.
While it isn't clear whether that crosswalk will be ready in time, it might not help ease the transition very much. Few EHRs today use the SNOMED language, so doctors aren't used to it. Moreover, the same degree of specificity in documentation will be required for ICD-10, however the codes are produced, Hock pointed out.