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MGMA believes ICD-10 compliance date is unworkable

ENGLEWOOD, Colo., Aug. 19, 2008 - The Medical Group Management Association (MGMA) is extremely disappointed that the Centers for Medicare & Medicaid Services (CMS) has called for an Oct. 1, 2011, compliance date for full implementation of the International Classification of Diseases, Tenth Revision (ICD-10) code sets. MGMA supports the move to ICD-10, but contends that the date proposed in the regulation is not workable.

The health care industry uses the ICD code sets, developed by the World Health Organization, to identify patients’ diseases, signs, symptoms, abnormal findings, complaints and causes of injury or diseases.
“The proposed regulation simply does not give the industry the time necessary to implement ICD-10,” stated William F. Jessee, MD, FACMPE, MGMA president and CEO.

The government must overcome numerous challenges before the health care industry can fully implement ICD-10. The proposed rule for the next generation of the Health Insurance Portability and Accountability Act (HIPAA) electronic transactions (ANSI X12 version 5010), released with the ICD-10 proposed rule, must be put in place prior to ICD-10 and MGMA believes this will take several years for full implementation and testing.

“We agree strongly with the recommendation from the government’s own advisory body, the National Committee on Vital and Health Statistics (NCVHS), that implementation of the 5010 transactions standards is a prerequisite to ICD-10. The two should not be implemented simultaneously,” said Jessee. MGMA contends that CMS should wait at least three years after the conversion to 5010 before moving the health care industry to ICD-10.

Because ICD-10 contains 10 times the number of codes as ICD-9, the newer code set will require vast changes for medical groups, hospitals and other health care facilities. “Moving to these new code sets has the potential to be the most complex change for the U.S. healthcare system in decades,” Jessee says.

ICD-10 will have considerable impact on clinical documentation, administrative transactions and quality-improvement programs. Recent research by the MGMA Legislative and Executive Advocacy Response Network (LEARN)  indicated that 95 percent of respondents in medical practices would have to purchase software upgrades for their practice management systems or buy  all new software;  63.5 percent concluded that they would have to purchase code-selection software.  In addition, 83.5 percent of LEARN respondents stated that they did not think public and private health plans would be ready to accept claims with ICD-10 codes by October 2011.

MGMA believes that CMS has not recognized the magnitude of this effort for each sector of the health care industry and the costs that medical groups will face to implement it. The Association will closely review the government’s cost and benefit assertions laid out in the regulation. 

“As we have seen with the protracted implementation of other requirements of (HIPAA), such massive system and workflow changes necessitate coordinated actions among medical groups and their vendors, clearinghouses and health plans. CMS should have instituted pilot testing in a broad array of clinical settings before publishing the rule to fully ascertain the impact of ICD-10 on the health care system. It is a recipe for disaster to force such a change without pilot testing and allowing sufficient time for implementation,” stated Jessee.
To avoid serious disruption to the health care system, MGMA urges CMS to follow the recommendations of the NCVHS and reconsider the unworkable Oct. 1, 2011, implementation date in the proposed regulation. MGMA believes that the health care industry should adopt ICD-10 only after the 5010 transaction standards are fully implemented and tested. 

About MGMA

MGMA, founded in 1926, is the nation’s principal voice for medical group practice. MGMA’s 21,500 members manage and lead more than 13,500 organizations in which more than 270,000 physicians practice. MGMA’s core purpose is to continually improve the performance of medical group practice professionals and the organizations they represent. MGMA headquarters are in Englewood, Colo.

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