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ASA comment letter to CMS regarding ICD-10

October 15, 2008

Mr. Kerry Weems
Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-0013-P
P.O. Box 8016
Baltimore, MD 21244-8016

Re: HIPAA Administrative Simplification: Modification to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS; Proposed Rule

File Code: CMS-0013-P

Dear Mr. Weems:

The American Society of Anesthesiologists appreciates the opportunity to comment on this Proposed Rule. We acknowledge that a transition from ICD-9-CM to ICD-10 CM (and ICD-PCS for hospitals to use to report their portion of an inpatient procedure) will offer many benefits and enhancements to health care reporting and tracking and we are not objecting to the switch to ICD-10-CM and ICD-10-PCS. However, ASA has concerns with respect to the proposed implementation timeframe.

As proposed, the entire health care community will need to initiate a multitude of processes required to adopt a new version of the electronic health care standards on a schedule that will enable implementation of Version 5010 in 2010. This transition to Version 5010 is in and of itself a massive undertaking requiring careful review and preparation for widespread, systematic changes. ASA has noted its concerns about the proposed change to the new 5010 in a separate comment letter. As proposed, the health care community will have to begin the transition process to ICD-10-CM (and ICD-10-PCS) before work on the 5010 is completed. This places an enormous burden on a system that already faces tremendous challenges. In addition, the simultaneous implementation and preparation efforts will increase opportunities for systematic issues, errors and unanticipated issues and consequences that could detrimentally impact the ability of providers to administer their practices and payers to properly reimburse providers for their patient care services.

We join with many other organizations in stating that a compliance date of October 2011 is unworkable.

The transition from ICD-9-CM (Volumes 1 and 2) to ICD-10-CM involves much more than learning new codes and revising a superbill. The ICD-9-CM diagnosis codes are the keystone to many health care systems and the change will impact many processes in the system including:
  • Coding software
  • DRGs
  • LCDs
  • Quality Management
  • Utilization Review
  • Registries
  • Disease Management
  • Performance Measures and Pay for Performance/Reporting Programs
All of these aspects of the health system involve many stakeholders, both within an organization such as a hospital, and between organizations, such as between practices, software vendors and payers. The implementation timeframe must allow sufficient time for all of these stakeholders to properly revise and test their systems before a successful transition can occur. Failure in this regard could result in disruptions of chaotic proportion that could ultimately detrimentally impact patient care.

ASA strongly believes that the implementation date for ICD-10 should be contingent on a successful conversation to Version 5010. We agree with others who have determined that a smooth and successful transition to ICD-10 will require a three year period that can start only once the 5010 conversion is complete. If the 5010 is implemented in April 2010 as proposed, the ICD-10 implementation date should be set no sooner than October 2013. The fact that such a broad and diverse group of health care stakeholders agree on this delay should not be taken lightly.

We thank you for your consideration of our comments and stand ready to assist CMS in identifying appropriate time frame and other means to ensure a smooth transition to ICD-10-CM and ICD-10-PCS.


Jeffrey L. Apfelbaum, M.D.
American Society of Anesthesiologists