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Winter 2009

Proposed ICD-10 Rule Published

Sharon Hughes MBA, RHIA, CCS
Senior Director of Coding and Auditing, Anesthesia Business Consultants, LLC (ABC)

As part of our desire to keep both clients and readers up to date, the Communiqué has been printing compliance information since its inception. In the Compliance Corner, we will now formally keep you abreast of the various compliance issues and/or pick out a topic that would be of interest to most of our readers.

Quality information leads to quality healthcare.

Have you had time to read the Federal Register proposed rule on adoption of the ICD-10 published last August? I’ve noted a few interesting items for you from the following proposal. The Notice of Proposed Rulemaking (NPRM) for the adoption of ICD-10-CM and ICD-10-PCS was published in the August 22, 2008 Federal Register (CMS-0013-P) (

ICD-10 was adopted by the World Health Assembly in 1990. Currently, the United States is the only G7 nation (the other G7 nations are Canada, France, Germany, Great Britain, Italy and Japan) continuing to use ICD–9 for morbidity reporting. Furthermore, Great Britain, Denmark, Finland, Iceland, Norway, Sweden, France, Australia, Belgium, Germany, and Canada use a clinical modification of ICD–10 for reimbursement and/or administrative purposes.

The lack of specificity in ICD–9–CM also limits our ability to develop rapid interventions for emerging diseases affecting international populations. Diagnosis and procedure information are captured from administrative data that are submitted on health care claims, and admission and discharge summaries, but if the codes do not match the international standard and are unable to be compared, their significance is lost. Additionally, hospitals utilize diagnosis and procedure codes for utilization review, disease management, and research. Therefore, in addition to the need for precise diagnosis and procedure codes for payment purposes, detail and precision in coding are critical to the national and international health care community for mortality reporting, biosurveillance, treatment of patients, hospital management, and research. (See Figure 1 below).

These benefits would expand communication and interoperability capabilities for biosurveillance and disease reporting at an international level. As noted in a recent report, The Effectiveness of ICD–10–CM in Capturing Public Health Diseases,‘‘ * the use of ICD–10–CM has great implications for our entire nation since public health diseases, which include epidemic and other diseases related to bioterrorism, are generally able to be captured in a more specific way when using the ICD–10–CM system.’’ BioSense, CDC’s early event detection system, currently uses ICD–9–CM. Improved clinical detail would be a benefit to a national system designed to improve the nation’s capabilities for disease detection, monitoring, and real time health situational awareness. As noted in the May 2004 NCVHS Workgroup on Quality Report, titled “Measuring Health Care Quality: Obstacles and Opportunities”, most other industrialized nations have already transitioned to ICD–10, requiring a painstaking crosswalk of United States diagnosis codes to make international comparisons. However, even with a crosswalk, comparisons are problematic given that changes to ICD–10 which represent a new understanding of disease (such as the myeloproliferative disorders and myelodysplastic syndrome now being recognized as hematologic malignancies which are classified as neoplasms of uncertain behavior in ICD–9–CM) affect data analysis at the State, national and international level. Because the U.S. does not currently use ICD–10–CM and ICD–10–PCS, there is insufficient data to quantify the results of these benefits.

Look for more beneficial information regarding the costs and compliance issues of transforming into the new world of coding in the upcoming issues of Communiqué.