This web-exclusive Journal column highlights public policy initiatives at the federal- and state-level that impact the HIM profession, including news on AHIMA’s national and affiliated state advocacy initiatives, Congressional updates, news from federal regulatory agencies, public policy updates from state legislatures, and AHIMA’s public policy initiatives with other organizations.
By Sue Bowman, MJ, RHIA, CCS, FAHIMA
The World Health Assembly adopted ICD-11 in May of this year. Earlier this month, Sue Bowman, MJ, RHIA, CCS, FAHIMA, AHIMA’s senior director of coding policy and compliance, participated in a National Committee on Vital and Health Statistics (NCVHS) Subcommittee on Standards ICD-11 Expert Roundtable. NCVHS serves as the statutory public advisory body to the Secretary of Health and Human Services for health data, statistics, privacy, and national health information policy and the Health Insurance Portability and Accountability Act (HIPAA).
Evaluating pathways and making recommendations to the HHS Secretary regarding adoption and use of ICD-11 was identified by NCVHS as an area of focus in 2019. In February of this year, NCVHS recommended to the Secretary that the Department of Health and Human Services (HHS) use sub-regulatory processes to make version updates to the ICD (e.g., ICD-11) in the same way it handles updates to all the other named HIPAA standards. NCVHS stated that the timeline and experience of the update from ICD-9-CM to ICD-10-CM/PCS illustrates why the process must be simplified. NCVHS also recommended that HHS invest now in a project to evaluate ICD-11 and develop a plan that will enable a smooth and transparent transition from ICD-10 to ICD-11 at the optimal time. NCVHS believes the ICD-11 evaluation project is an ideal test for a set of updated criteria for adoption of health terminology and vocabulary standards that it put forth. Examples of these criteria are that health terminology and vocabulary standards should be clear in purpose, expected outcomes, boundaries, and guidelines for use and designed to perform well for its stated purpose; and supported by research confirming the benefits and estimates of cost, including burden of use, adoption, and implementation.
ICD-11 transition planning does not include replacing the US procedure coding system, ICD-10-PCS, since ICD-10-PCS is completely separate from ICD-10 and updates to this system do not need to be tied to updates to ICD (and vice versa). NCVHS recommended in the February letter referenced above that HHS clarify that ICD-10-PCS will not be updated with the transition of ICD-10 to ICD-11.
Roundtable participants included terminology experts, economists, and health researchers. The objectives for the ICD-11 Expert Roundtable were to:
- Develop a shared understanding of lessons from the ICD-10 planning process/transition and the differences between ICD-10 and ICD-11
- Reach consensus on the research questions to be answered to inform evaluation of cost and benefit of transition from ICD-10 to ICD-11 for mortality and morbidity—and to identify impacts of not moving to ICD-11 for morbidity
- Identify key topics/messages to communicate to the industry to foster early stakeholder engagement and preparation for the transition to ICD-11
The desired outcome of the meeting was to produce a set of questions to help guide HHS in developing research. NCVHS plans to send a letter to the HHS Secretary later this year outlining the key research questions that were identified during the expert roundtable.
Potential research topics that emerged during the roundtable discussion included:
- Identification of use cases for ICD-11
- Assessment of whether a US clinical modification of ICD-11 will need to be developed
- Evaluation of costs and benefits of transitioning to ICD-11, considering different use cases and alternative transition timelines
- Evaluation of the fitness of ICD-11 to support the convergence of clinical, social, and administrative standards
- Analysis of the impact on clinician burden, quality of care, and value of healthcare data
- Analysis of the impact on different models of care
- Assessment of the tools needed to reduce workflow burden and improve documentation quality
- Evaluate alternative and innovative approaches to ICD-11 training and ongoing support
- Assess the impact of ICD-11 on the coding workforce and potential job role changes
Research needs to be conducted in the near-term to determine the benefits and costs of potential different implementation approaches and time frames, as well as to ascertain the costs and implications of not implementing ICD-11 in a timely manner. How soon could the US implement ICD-11 if there was no need to develop a clinical modification and/or HHS accepted the NCVHS recommendation to use sub-regulatory processes to adopt ICD-11?
Regarding the last bullet above, the group discussed the expectation that ICD-11 will facilitate greater auto-generation of codes from clinical documentation, resulting in coding professionals’ roles transforming into that of an auditor or other data quality assurance responsibilities.
The roundtable also raised questions around how related terminologies for domain-specific concepts (e.g., medications, toxins, devices) could be leveraged to complement ICD-11.
It was pointed out that the World Health Organization (WHO) believes migration to ICD-11 will be less expensive than the transition to ICD-10 due to automation and the development of new tools, which include coding, browsing, translation, and mapping tools. WHO has also indicated there are no plans to develop ICD-12. ICD-11 has been built in such a way that it can be expanded for the foreseeable future without the need to develop a new version.
The group recommended that HHS provide leadership on strategic outreach and communication about the ICD-11 transition. Both NCVHS members and roundtable participants felt it is important to convey a sense of urgency to get started on securing research funding and beginning to conduct the necessary research.
For more information about ICD-11 and the tools and resources WHO has developed to facilitate its implementation and use, visit the ICD-11 web site.
Sue Bowman (firstname.lastname@example.org) is senior director, coding policy and compliance at AHIMA.