Yesterday, HHS dropped the bomb that ICD-10 has been delayed. Everyone is still trying to figure out what that means exactly. The reason there are questions is that it seems that HHS can’t just unilaterally delay the compliance date. I’ll admit that I’m not an expert in the regulatory processes, but as best I can tell HHS intends to go through the regulatory process to delay ICD-10.

The part of the press release in question says, “HHS will initiate a process to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10).”

My gut feeling is that the process for postponing implementation of ICD-10 is more of a formality that HHS has to go through, but maybe there’s something that could hijack that process. I’m guessing there won’t be any issues or HHS wouldn’t have made the announcement yet.

The words “certain health care entities” in the above quote have a lot of people wondering what it means. Does that mean ICD-10 will be delayed for certain entities and not others? This would be odd if it were the case, but it seems that it could be a possibility.

This ICD-10 delay announcement comes shortly after HHS met with AMA who it seems is one of the major voices behind delaying implementation of ICD-10. A voice with a decent amount of money and lobbying power in Washington. HIMSS quickly published a press release calling for HHS to Maintain the ICD-10 Implementation Deadline. HIMSS cites that the health industry has been prepping for ICD-10 for the past 3 years. I’d add that the October 1, 2013 deadline is still 20 months away. You’d think that would be plenty of time to implement ICD-10, no?

After this delay some voices are starting to ask if HHS should consider just bypassing ICD-10 altogether and go straight to ICD-11 which comes out in 2014. Keith Boone wrote a post on this and highlights what I believe is a key reason why HHS won’t skip ICD-10 and go straight to ICD-11: investment in ICD-10. As I said in the comments of Keith’s post:

What a terrible thing to consider when making policy (although, sadly the stark reality): what’s the investment companies have made in ICD-10?

In business they’d call this a sunk cost and choose the best path forward. Unfortunately politics doesn’t quite work that way and you’re right that it’s quite unlikely that HHS will jump directly to ICD-11 and anger all those who’ve invested so heavily in ICD-10.

Tom Sullivan adds to the discussion for why we should move to ICD-11 in the comments of that post as well:

When I started covering ICD-10, I was a proponent. But given that ICD-10 really is antiquated — as Dr. Chute explained to me on Monday it’s based on thinking about medicine and technology from the 1980′s — it seems a shame for the U.S. to spend literally billions getting there, only to reach what is essentially a classification system at least approaching the end of its lifecycle, or perhaps what ought to be the end of its lifecycle rather than the beginning. And it’s not just the linkages to SNOMED that make ICD-11 attractive (though they certainly do); a system that is semantic web-aware, with rich information spaces, definitions of terms, genomic underpinnings, a foundational fabric, and I’m sure there will be more in there, just makes so much more sense than ICD-10.

At any rate, I view the delay as an opportunity to re-evaluate our approach and maybe, just maybe, put politics aside and opt for the system that has the most potential to improve public health with data.

So perhaps adopting ICD-11 is not really idealist, after all, but pragmatic!

One discussion on the #HITsm chat today on this subject was around the real benefits of ICD-10. As with many things in healthcare, the arguments seem to center around benefits to healthcare in general and to public health. As a doctor advocate myself, I can see why they wouldn’t want to add the burden of ICD-10 on their shoulders when it doesn’t help them directly provide better care. I’m not saying that doesn’t mean we shouldn’t do things anyway, but it’s not surprising that we’re seeing resistance from doctors to ICD-10.

One other comment people are making about the ICD-10 delay is that it could be politically motivated in a year when Obama is seeking reelection. I’m not sure how much influence delaying or not delaying ICD-10 will have on the presidential campaign. Seems like a pretty small deal in the grand scheme of things. I can’t imagine the major media people and the regular voters ever even getting wind of the delay. However, maybe there’s some important donors and influencers that I don’t know about that this appeases.

My heart goes out to all those HIMSS exhibitors that’s major strategy was based around ICD-10. Every PR person that pitched me an ICD-10 discussion I replied that I’d gotten enough ICD-10 at AHIMA. Now I’m getting some pitches from these same companies saying they’d like to discuss the ICD-10 delay. So, they’re trying to make the most of it.