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Letter from HBMA President Jeanne Gilreath, CHBME to Senate Majority Leader Harry Reid (D-NV) and Minority Leader Mitch McConnell (R-KY)


March 27, 2014




The Honorable Harry Reid                                         The Honorable Mitch McConnell

Senate Majority Leader                                              Senate Minority Leader

United States Senate                                                  United States Senate

Washington, DC 20510                                              Washington, DC 20510


Dear Speaker Boehner, Leader Pelosi, Leader Reid, and Leader McConnell:


The Healthcare Billing and Management Association (HBMA), along with many other organizations whose members have a strong vested interest in the decision to move ahead or delay action on ICD-10 implementation, were shocked and disappointed by the proposed delay included in the SGR patch legislation announced yesterday.  While the concerns about moving ahead with ICD-10 are well known, a decision to delay the effective date should be done only with a full discussion of the consequences and implications of that decision.


To our knowledge, there has not been a single Congressional hearing on the pros or cons of delaying the ICD-10 effective date.  We find it regrettable that there was no effort to determine whether there were alternatives that might satisfy all parties or how ICD-10 implementation could have proceeded in a more cost-effective, less disruptive manner.


It has been no secret that some segments of the healthcare industry have consistently opposed the adoption of ICD-10.  We sympathize with those groups and share many of their concerns.


But once the decision had been made that we were moving forward with ICD-10 and a firm effective date had been established, our members and others set about the task of investing millions of dollars and person-hours into making ICD-10 implementation work.


As privately owned businesses, our member companies have funded their own ICD-10 transition. Based on company size, this funding has ranged from tens of thousands of dollars to several million.  We believe that our members’ experiences are comparable to many other healthcare providers and industry organizations and many share our concerns that a delay of ICD-10 CM will:


  1. Defer, for no less than another year, the tangible benefits that more precise diagnostic codes will provide to improve patient care as well as defer taking advantage of the long-overdue enhancements to quality measures, disease tracking and prevention, public health and enhanced medical research.



  1. Multiply – not delay – the aforementioned costs associated with implementation.  Just as the delay from 2013 to 2014 “shut down” providers’ implementation efforts for almost a year, this delay will do the same.  Backing down implementation will create new costs; re-ramping up implementation will create new costs; reviving lost training (learning a complex new code system has a “half-life” of about six months) will create new costs.  In addition, technical updates for systems, employee training, workflow and process changes and hundreds of other operational adjustments will have to be suspended, reworked, or mothballed for another year.
  2. Destroy regulatory credibility.  Every authoritative organization and Government agency has been adamant there will be no delays; first in 2013 and in 2014 until today.  If Congress votes to delay implementation of ICD-10, will anyone believe it is really going to happen in 2015, if ever?  It is certainly doubtful.  In fact, we are concerned that this delay will become another step in death-by-delay and ICD-10 will never happen.
  3. Make ICD-10 expertise scarce.  Certified ICD-10 experts and trainers will find it necessary to find other employment and, when finally needed, will be unwilling to risk a repeat of this delay.  Attracting trainers and experts will become more difficult as the knowledge and skills will be deemed an unreliable career choice.
  4. Facilitate additional delays.  If any excuse is a good excuse, there will always be many others offered, such as the pending introduction of ICD-11, or other industry changes, or federal mandates (such as Meaningful Use, etc.).


Thus we believe that a delay of the ICD-10 implementation date just six months prior to the effective date will compromise the industry in many negative ways.  More importantly, we have no doubt that this action, if approved, will add immeasurably to the cost of healthcare in this country.


HBMA recognizes and respects the concerns that led to the inclusion of the ICD-10 implementation delay in the bill to address the SGR payment reduction.  But this is the wrong place and wrong time to adopt a delay.  We are simply too far along in the implementation process.  Adoption of a delay at this juncture would, we believe, do more harm than good.


Please keep in mind:  Delay does not mean readiness!


Your consideration of these concerns is greatly appreciated.



Jeanne Gilreath, CHBME
Healthcare Billing and Management Association