May 29, 2002
Chris B. Fraizer
AAPC Position Statement
Possible Replacement of ICD-9-CM, Volumes 1& 2 (Diagnosis) with
ICD-10-CM
National Committee on Vital and Health Statistics
Subcommittee on Standards and Security
Thank you for the opportunity to present comments representative of the American Academy of Professional Coders (AAPC). I am a technical analyst for the AAPC and here today to summarize the salient issues facing the Academy and its 28,000+ members.
The American Academy of Professional Coders (AAPC) was established more than a decade ago for reasons outlined in our mission statement:
To maintain the standards of professional coding, the AAPC must ensure the standardization of good coding practice among its members. We do this through an accreditation process that ensures competency standards in entry-level coders and the development of curriculum that meets industry standards for advanced and specialty coders. Members are required to earn 18 to 24 continuing education credits each year to maintain certification on the provider (CPC) and hospital (CPC-H) levels. Credits are available through seminars offered at the AAPC national conference, local AAPC chapter meetings, educational materials developed by the AAPC, and materials submitted to us for CEU approval from private vendors.
As such, the primary concerns of the AAPC are as follows:
We address these concerns in the following statement.
The transition, which is inevitable, raises our first concern: Will there be a timeline developed and published in relation to implementing the new coding set?
Administrative simplification provisions of the Health Insurance Portability and Accountability Act (HIPAA) require a national health information system that standardizes the electronic transmission of administrative and financial health care information. Standardization applies to diagnostic and procedural codes. The code sets that meet HIPAA requirements, and Congress’s approval, will be the code sets used by health plans, health care clearinghouses, and health care providers transmitting information electronically.
An initial deadline for the rule finalizing code sets has been delayed, and, nationally, we are using the diagnostic and procedural codes that were approved in a temporary ruling (ICD-9-CM, CPT, and HCPCS Level II). The AAPC training materials emphasize these code sets and will continue to do so while they are the standard coding systems.
If we assume the replacement is I-10, the differences between ICD-9-CM and ICD-10-CM represents very fundamental changes in the way we now code for diagnosis. According to information about ICD-10-CM on the NCHS site, the replacement Tenth Revision, compared to the Ninth Revision, presents:
In Australia, the change-over from ICD-9 to ICD-10 took three years, according to an article in Coding Matters (newsletter of the National Centre for Coding in Australia, July 1995). Coding workshops held throughout Australia were scheduled during the final year of the transition period; however, training the instructors preceded national training of the provider and facility coders.
The process of educating membership raises our second concern: Will NCHS or NCVHS provide training manuals (or designate a supplier of training materials) similar to the training manual provided for ICD-10-PCS?
The AAPC develops educational materials based on the requirements of a diverse membership spread across many medical specialties and ranging in experience from entry-level coders to coders with up to 30 years experience. We have members certified to teach coding through AAPC sanctioned seminars and workshops, consultants working with practices and facilities, and compliance (fraud and abuse) specialists. The AAPC has been offering ICD-10 seminars for about two years in preparation for the transition to the new code set. However, before the AAPC embarks on a hands-on education program, we must prepare materials that introduce the anticipated changes in the 10th revision. For example, Australia produced an information packet on-line to facilitate the transition to ICD-10-AM (Australian modification). The packet was “designed so a clinician or other health professional may view the material on screen and then download all of the package or only particular specialty areas.” Those downloading the material could use the information for self-learning, classroom teaching, or for presentations at clinical meetings.
The AAPC also anticipates developing training packages based on official rules and guidelines. Again, the AAPC encourages an adequate transition period that includes direction from the NCHS and NCVHS. Similarly to the process in Australia, the AAPC would dedicate time to training our technical staff, and time for staff to develop materials for training I-10 specialists. The AAPC envisions national seminars, as well as workshops on a smaller scale offered through the local chapters.
Certification is the gold standard for professional coders and the requirements for certification and education beyond the certification process will always be paramount to the Academy. How do we prepare our coders in a time of overlapping coding sets?
Currently, certification tests for provider and facility coders are developed in our national office (Salt Lake City) and revised on an annual basis in accordance to the diagnostic and procedural code changes. Other adjustments are made throughout the year, as needed, and reported in AAPC’s monthly Coding Edge newsletter as well as on the AAPC web site. The transition in coding sets complicates the certification, training, and reporting processes, at least initially. This change in diagnostic coding sets requires the development of an adjunct competency evaluation for those already certified as professional medical coders. The adjunct evaluation would complement the skills and knowledge of the established coder but, eventually, the new code set must be incorporated into testing instruments for national certification. The timing here is critical due to the work required to produce the national exams and the presumed competency evaluation. The AAPC also plans to publish transition alerts, both on-line and in the monthly newsletter, to keep membership apprised of this important event.
Ample time for education and training during this transitional period is a primary concern for the AAPC. We estimate that a coder needs at least one year of education and experience, combined, to certify through either one of our exams. An apprentice program is available; however, the apprentice retains that designation until there is evidence that the coder has achieved certain competency levels. The transition complicates the apprentice program because of the anticipated interruption in attaining certain skills, such as a proficiency in diagnostic (ICD-9-CM) coding.
In summary, whatever the system implemented, the AAPC encourages a 30-month transition period, at the minimum, to prepare for the implementation of the revised diagnostic coding. During this time, the AAPC looks forward to participating in the planning process as we, also, anticipate your guidance during this critical time.