September 24, 2002

John R. Lumpkin, M.D., M.P.H.
Chair
National Committee on Vital and Health Statistics
Illinois Department of Public Health
535 W. Jefferson Street
Springfield, Illinois 62761

RE: Possible NCVHS Recommendation to Migrate from ICD-9 to ICD-10 Diagnosis and Procedure Codes

Dear Dr. Lumpkin:

We understand that the Subcommittee on Standards and Security is considering recommending that the Department of Health and Human Services adopt ICD-10-CM and ICD-10-PCS as a replacement for the diagnosis and procedure codes contained in ICD-9. The undersigned organizations urge the National Committee on Vital and Health Statistics (NCVHS) to postpone making any recommendations to the Secretary of Health and Human Services that would require the entire health care industry to convert to ICD-10 for diagnosis and procedure codes until the Committee has completed the following:

• Evaluated the impact of migration to ICD-10 diagnosis and procedure codes on all aspects of the industry, including physicians, hospitals, health plans (including Medicare and Medicaid), and other major segments of the industry;
• Prepared a detailed cost/benefit analysis of migrating to ICD-10 for diagnosis and procedure codes; and
• Considered all cost-effective alternatives.

We believe that NCVHS endorsement and recommendations should consider the impact of these code changes on the industry as a whole and evaluate the costs and benefits before proceeding to ICD-10. No such detailed analysis has been completed to date. A recommendation in the absence of any impact and cost analysis is premature. We request that these analyses be undertaken and/or commissioned by NCVHS with industry participation.

The industry is already allocating tremendous resources to comply with the initial HIPAA administrative simplification standards. Over the next several years, covered entities will be implementing regulations relating to standard identifiers, claims attachments, security, privacy, and ongoing modifications to transactions and code sets. An industry impact analysis should consider these current obligations in addition to the extensive systems changes required by ICD-10. The added burden of implementing ICD-10, a wholesale coding change, may put at risk the ability of the industry to efficiently address demands already required under HIPAA.

Recently, the Government Accounting Office (GAO) analyzed the potential impact of changing from ICD-9 to the ICD-10 coding standards. As stated in the GAO report (GAO-02-796):

“The design and logic of 10-PCS raise concerns about potential challenges in its implementation, including coding accuracy and the availability of useful data. In addition, the existing health care administrative system would need to be changed significantly to accommodate 10-PCS, imposing additional financial costs and administrative burdens on members of the health care industry, such as providers and payers, who are currently undertaking changes to comply with HIPAA.”

We believe that the Committee should consider these issues before any recommendation is sent to the Secretary.

Thank you for your consideration.

Sincerely,

American Association of Health Plans
American Public Human Services Association/National Association of State Medicaid Directors
Blue Cross Blue Shield Association
Health Insurance Association of America
Joint Commission on Accreditation of Healthcare Organizations

cc: Simon P. Cohn, M.D., M.P.H., FACP
Chairman, Subcommittee on Standards and Security