AHIMA Letter to Secretary Thompson on the Adoption of ICD-10

July 24, 2003

The Honorable Tommy Thompson
Secretary
Department of Health and Human Services
200 Independence Avenue SW
Washington, DC 20201

Dear Secretary Thompson:

I commend your leadership in making SNOMED-CT available through the National Library of Medicine. I was in the audience when you addressed the National Health Information Infrastructure (NHII) conference on July 1 and I agree with your assertion that a clinical reference terminology is essential for an interoperable health information infrastructure. As CEO of AHIMA, I represent its 46,000 members who manage personal health record and data systems. We know all too well that the information content of the NHII is as important as its technology architecture. AHIMA fully supports the use of SNOMED-CT and will do all we can to further its full deployment and use.

At the same time, AHIMA urges the Department to take quick and decisive action to adopt ICD-10-CM (International Classification of Diseases, 10th edition, Clinical Modification) and ICD-10-PCS (International Classification of Diseases, 10th edition, Procedure Coding System) to replace the obsolete ICD-9. Despite being developed way back in the early '70s and implemented in the US in 1979, ICD-9 continues to serve as the basis for payment, research, policy setting, quality improvement, health care management and many other uses of vital importance. To implement SNOMED-CT without adopting contemporary classifications is like driving a model T in the Indianapolis 500-It can be done but it won't get you to the winner's circle. We simply won't realize the full benefit of a common reference terminology if we aggregate that language into a 30-year old classification system. One only has to contemplate how medical practice has changed in 30 years to understand the gross inadequacy of ICD-9.

The groundwork for transition to ICD-10 has been laid. In 1993 the Department's National Committee on Vital and Health Statistics (NCVHS) reported that ICD-9-CM was outdated and went on record supporting the immediate commitment of the US to migration to ICD-10. That work has been done and ICD-10-CM, developed by the National Center for Health Statistics/CDC, is ready for implementation. Furthermore, in 1998, CMS commissioned the development of a replacement system to code inpatient procedures and ICD-10-PCS is also now ready for implementation.

The risks of further delay are very serious:

1. The US is out of step with all other developed countries that have already adopted the 10th edition of the ICD. Other countries use it to classify the incidence of disease as well as the causes of death. The US is using ICD-10 for cause of death reporting only and ICD-9 for disease reporting. Our national data systems are being rendered useless. At a time when SARS and other epidemics are just an airplane flight away, the US must be part of the world health data community.
2. A map between SNOMED-CT and ICD needs to be built to derive full benefit from SNOMED. A map is the crosswalk from the clinical reference terminology to the classification system. It makes no sense to build a map to an obsolete classification system. In fact, maps from SNOMED-CT and ICD-10 are under development for use in other countries and the US will benefit from this work. The electronic health record permits automated assignment of ICD codes. However, the construct and greater specificity offered by ICD-10-CM and ICD-10-PCS will greatly facilitate this application. Availability of computer-aided coding applications would relieve the shortage of expert coders and enable them to perform other critical data management roles in the electronic health information management environment.
3. Even if ICD-10-CM and ICD-10-PCS were in place today, it will take several years to realize full benefits from the improved aggregate databases. For example, coded data based on ICD-10 would permit improved underwriting and payment methodologies, more precise research sampling, tracking and trending of patient outcomes and costs, more reliable performance data for consumers, to name just a few. We must move from the paralysis that seems to have characterized the debate about code sets toward a firm and expedited update schedule.

Despite the compelling reasons for the immediate adoption of ICD-10-CM and ICD-10-PCS, there is still confusion and misinformation leading to inaction. Others allege that:

1. The new systems are too complex for the skills of coders. AHIMA and CMS have conducted field tests that not only disprove this, but, rather, reveal that the improved specificity aids coders and results in more accurate data.
2. The IT vendors cannot handle the change. This is simply not the case. Industry testimony before NCVHS in 2002 revealed that major vendors have already made provisions for ICD-10 and need only a reasonable implementation schedule to make the transition.
3. The payers cannot bear the cost of the necessary computer upgrades. Yet, payers will be key beneficiaries of improved data. Like the NHII overall, upfront investment is needed to reap enormous long-term benefit.
4. The availability of SNOMED-CT mitigates the need to replace ICD-9. In fact, the opposite is true. Valid and standard maps to group from a highly specific vocabulary to a classification are urgently needed. To continue to use ICD-9 diminishes the value of the national investment in SNOMED-CT.

AHIMA urges you to promulgate a notice of proposed rule making to adopt ICD-10-CM for use in all healthcare settings and ICD-10-PCS for use in reporting hospital inpatient services. Modernization of code sets is an essential building block in the NHII and we look forward to working with the Department to make this important change happen soon.

I would appreciate the opportunity to address your questions or concerns and to share more comprehensive AHIMA testimony and the results of our research on this topic. I can be reached at 312-233-1166 or linda.kloss@ahima.org. You can also contact Dan Rode, vice president of policy and government relations in our Washington DC office at 202-659-9440 or dan.rode@ahima.org.

Sincerely yours,

Linda L. Kloss, MA, RHIA
Executive Vice President/Chief Executive Officer

cc: Barbara Siegel, MS, RHIT, 2003 president, AHIMA

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