September 23, 2002

The Honorable Tommy G. Thompson
Secretary
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, D.C. 20201

Dear Secretary Thompson;

The medical organizations listed below are writing to register our concerns regarding the possible implementation of ICD-10-PCS to replace ICD-9-CM, Vol. 3 and to state our strong preference for the investigation of Current Procedural Terminology (CPTÒ) as a viable candidate to meet the inpatient coding needs of hospitals and other facilities. Our preferences are a result of many years experience with the CPT code set and with the CPT editorial process. They are also based on the serious technical limitations, educational needs, system changes and overall costs that will be required to implement a new coding system as fundamentally different as ICD-10-PCS.

We believe that the implementation of ICD-10-PCS will only add to the regulatory burden faced by hospitals, physicians and other health care providers. We find it ironic that the imposition of a more complex coding system is being contemplated as your own Advisory Committee on Regulatory Reform is urgently seeking solutions to remove or eliminate the regulatory burden already existing in federal programs. While we understand that ICD-10-PCS is only being considered to replace ICD-9-CM, Vol. 3 for inpatient coding and not for professional services, a change of such magnitude must be considered in the context of the health care system as a whole and not compartmentalized.

It is unnecessary and potentially detrimental to replace ICD-9-CM, Vol. 3, which has served its purpose well and contains only approximately 4,000 codes, with ICD-10-PCS which contains nearly 200,000 codes and is unproven in any setting. The possible proliferation of all these codes will inevitably lead to a significant increase in data and reporting errors for inpatient procedure coding. A higher coding error rate could have system wide effects and the very real possibility of facility payment errors will affect physicians and other health care professionals who practice in hospitals.

Our organizations believe that this complex new coding system and excessive formalism contained therein will cause problems for users and will certainly require significant education of physicians, coders, and others billing or paying for these services. It is also important to consider the context of system changes. Currently many physicians, other providers, and payors are undergoing changes to comply with requirements for electronic transaction and privacy standards in the Health Insurance Portability and Accountability Act (HIPAA). System changes necessitated by ICD-10-PCS are in addition to expensive changes already taking place, making the overall bill even larger and the project more complex.

The lack of involvement of organized medicine and the leadership of allied health professionals in the development and maintenance of ICD-10-PCS is a substantial limitation. The undersigned medical organizations believe it is important for clinical leadership to be actively involved in the updating and maintenance of any procedure code set. The input of physicians who perform the services and procedures under consideration is an essential component of an accurate code descriptor. Similarly the input of physicians and other health care professionals in the decision making process is critical for coherence with generally accepted medical practice and clinical terminology. Our experience with the CPT Editorial process suggests that the input of other stakeholders, including the American Hospital Association, the American Health Information Association and the private payer community, is important and that broad clinical and administrative input on editorial decisions is essential for the development of a quality end product. The proliferation of new codes contained in ICD-10-PCS will involve a greater degree of complexity and the need for substantially more clinical decision making. The CPT Editorial process works well for all of its users.

CPT has been successfully used for physician services under the Medicare program since 1983 and associated with the Resource Based Relative Value Scale since 1992. Use of CPT to replace ICD-9-CM, Vol. 3 for facility payments would be a relatively minor change since it is already widely used in hospitals for outpatient and physician services.

The combination of educational needs and expenses, system changes and expenses, and the possibility of reporting errors, all result in plausible and serious system-wide disruptions and financial disorder. We believe that considerable further study is necessary regarding the cost-benefit of implementing ICD-10-PCS. In addition, any study on the costs and benefits of implementing a new inpatient code set should examine CPT as a viable alternative. We therefore urge the Department to consider adoption of CPT as a viable, workable alternative to ICD-10-PCS.

Sincerely,

American Academy of Dermatology Association
American Academy of Facial Plastic and Reconstructive Surgery
American Academy of Family Physicians
American Academy of Neurology
American Academy of Ophthalmology
American Academy of Otolaryngology-Head and Neck Surgery
American Academy of Pediatrics
American Association of Clinical Endocrinologists
American Association of Clinical Urologists
American Association of Neurological Surgeons
American Association of Orthopaedic Surgeons
American Association for Thoracic Surgery
American Association for Vascular Surgery
American Association of Electrodiagnostic Medicine
American College of Chest Physicians
American College of Emergency Physicians
American College of Nuclear Physicians
American College of Obstetricians and Gynecologists
American College of Occupational and Environmental Medicine
American College of Osteopathic Family Physicians
American College of Physicians – American Society of Internal Medicine
American College of Radiology
American College of Surgeons
American Medical Association
American Medical Group Association
American Osteopathic Association
American Society for Clinical Pathology
American Society for Therapeutic Radiology and Oncology
American Society of Addiction Medicine
American Society of Anesthesiologists
American Society of Cataract and Refractive Surgery
American Society of Colon and Rectal Surgeons
American Society of General Surgeons
American Society of Hematology
American Society of Plastic Surgeons
American Thoracic Society
American Urological Association
College of American Pathologists
Congress of Neurological Surgeons
National Association for Medical Direction of Respiratory Care
North American Spine Society
Society for Vascular Surgery
Society of Interventional Radiology
Society of Nuclear Medicine
Society of Thoracic Surgeons
Thomas Jefferson University, Nuclear Medicine Division