National Committee on Vital and Health Statistics (NCVHS), Subcommittee on Health Data Needs, Standards and Security

Public Meeting of April 15-16, 1997

Health Insurance Association of America

Written Testimony

The Health Insurance Association of America (HIAA)is a trade association representing 300 commercial health insurance companies, managed care plans and Blue Cross Plans. Our member companies provide products such as health insurance, dental insurance, disability income insurance, long term care insurance and Medicare Supplemental insurance. We are grateful for the opportunity to provide written testimony about medical / clinical coding issues to this committee.

The NCVHS is considering several issues related to medical / clinical coding and classification which are important to health insurers. Many of the questions raised by the Committee are answered in a recent HIAA research report, Insurance Company Coding and Claims Systems, A Survey (attached). HIAA distributed the survey to its member companies in the late summer of 1995. The survey asked companies about their coding and claims processing systems. Questionnaires were sent to approximately 120 company correspondents, representing HIAA's 300 companies. Of the 120 surveys distributed, HIAA received responses from 53 companies. Respondents represented approximately 30 percent of commercial insurers' health care business, processing an estimated 320 million claims in 1995.

In addition to providing NCVHS with a copy of the full report, here is some pertinent data taken from the survey.

· Diagnostic coding: for both inpatient and outpatient claims, almost all companies surveyed reported using ICD (94%);

· Procedural coding: for both inpatient and outpatient claims, most companies reported using CPT (87% I/P, 85% O/P);

· For other service claims, such as non-physician or hospital outpatient services, most companies use CPT (68% and 66% respectively);

· For DME and medical supplies no one system was used by a majority of companies surveyed:

· Respondents reported receiving almost one quarter (24%) of their claims electronically:

The following are some general comments that might help answer the questions to be addressed by the Subcommittee on Health Data Needs, Standards, and Security.

· During the 1994-95 deliberations of the NCVHS Subcommittee on Medical Classification Systems, HIAA submitted comments on the feasibility of establishing a single procedural coding system. Given the shortcomings of the present systems, principally the limited expansion possibilities for ICD and CPT, HIAA agreed with most other respondents that given a system that addresses the needs of interested parties, sufficient lead time to implement, and enough resources devoted to educating, disseminating, and maintaining such a system, a single system would be preferred to major revisions and maintenance of the current dual system of codes.

· During the discussions of the Subcommittee on Medical Classification Systems, commenters agreed that any nationally recognized coding system must address many aspects of users' concerns, from those of providers and payers to coders and researchers. For insurers and health plans, many files and applications are linked to policyholders or enrollees claims data. Not only would a system need to address billing/reimbursement applications, but enrollees'/patients' history, coverage and benefit determinations, and as more companies enter into the health care management area, service utilization and outcomes measurement.

· In terms of time frame, much depends on the current systems in place at the various end users and the extent of the changes that must be made compared to current systems, e.g., increase in the number of digits in the code system, switch from numeric to alphanumeric, etc. An additional factor is the manpower and/or funds that must be committed to the update. Relatively simple changes, such as existing annual code updates, can be accommodated in a relatively short time, e.g., several months or less given systems in place. More complex changes would require at least a year advance notice and most likely several years to implement, test, and coordinate. Additional resources may also be required to translate past data files to make them compatible with new systems and retain the ability to track and analyze data over time.