"The implementation of ICD-10 will create significant burdens on the practice of medicine with no direct benefit to individual patients' care," said Peter W. Carmel, MD, AMA president, in a statement. "At a time when we are working to get the best value possible for our healthcare dollar, this massive and expensive undertaking will add administrative expense and create unnecessary workflow disruptions."
While the AMA resolution goes further than the AMA or any other physician society has gone before in the long, tortured history of ICD-10, it seems to reflect physicians' frustrations with the wide range of burdens being placed on them right now, as much as their problems with ICD-10.
Carmel noted that the transition to the new codeset is beginning at a time when many physicians are struggling to implement electronic health records (EHRs). And, in an interview with InformationWeek Healthcare, AMA board of trustees chairman Robert Wah, MD, said, "I think this policy indicates the level of frustration with the regulatory and financial pressures that are being put on physician practices today."
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Among these pressures, he noted, are Medicare's intention to penalize physicians who don't adopt EHRs by 2015, and the very real threat of a 27.4% cut in Medicare fees on Jan. 1, 2012, unless Congress acts between now and then. Additionally, he pointed out, physicians have to cope with pressures to become medical homes and join or form accountable care organizations as reimbursement models change.
Wah made it clear that the House of Delegates was not just posturing in its statement. Still, he said he hoped that the Centers for Medicare and Medicaid Services (CMS) would be willing to open a dialog with the AMA on such issues as delaying ICD-10 implementation and reducing the number of codes in the set.
CMS responded to the AMA move with this statement: "Implementation of this new coding system will mean better information to improve the quality of healthcare and more accurate payments to providers. We will continue to work with the healthcare community to ensure successful compliance."
The AMA disagrees with both of CMS' contentions about ICD-10. "If it contributes to overall population health analysis, that will lead to quality improvement," said Wah. "But we don't understand how adding a five-fold increase in codes, going from 13,000 codes to 68,000 codes, is going to help a patient in my office."
What it will do, however, is vastly complicate the documentation of care, Wah argued. Many of the new codes, he pointed out, have nothing to do with the process of diagnosing patients, such as codes that specify whether they received a head injury from a baseball bat or a hockey stick.
The AMA is also concerned that payers may use the increased granularity of the codes to require documentation of minor subcategories as a basis for payment. This could result in nonpayment or delayed payment of many claims, Wah said.
Robert Tennant, senior policy advisor to the Medical Group Management Association (MGMA) agreed. "We don't know what the payment policies will look like," he told InformationWeek Healthcare. "And to make it more complicated, each health plan will have its own payment policy, so the physician and their coder will have to know what that plan policy will be in terms of documentation."
Both Wah and Tennant noted that the ICD-10 sets used in other countries have fewer codes than the version slated for use here does. In addition, they said, Canada and Australia--two of the nations that use ICD-10--have single-payer systems, which made the transition to ICD-10 much simpler than it will be in this country's multi-payer system.
MGMA has not taken as aggressive a stand as the AMA has on stopping ICD-10. But Tennant noted that MGMA has long expressed its concerns about the codeset. The group practice association would like to see CMS do a pilot of ICD-10 implementation before it forces everyone to undertake the expensive transition to the new codeset, he added.
A study conducted for MGMA in 2008 indicated that it would cost a typical 10-doctor practice about $285,000 to convert to ICD-10. The software cost associated with the transition would be only $15,000, according to the study. The big costs would come from increases in claims queries, reductions in cash flow, and, most of all, increased documentation time.
Tennant said he believed that the costs today would be even greater than in 2008, and the AMA also cited the study in support of its opposition to ICD-10.