Letter from The Honorable Kathleen Sebelius, Secretary – Department of Health and Human Services

Re: Possible Delay of Deadline for Implementation of ICD-10 Code Sets

Dear Madam Secretary:

The National Committee on Vital and Health Statistics (NCVHS) is the statutory advisory committee with responsibility for providing recommendations on health information policy and standards to the Secretary of the Department of Health and Human Services (HHS). Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), NCVHS is to advise the Secretary on the adoption of standards and code sets for HIPAA transactions, including the transition from ICD-9-CM to ICD-10 code sets.

These are unprecedented times in health care. The pace of change is extraordinary and the opportunity to improve the health and health care of our nation accelerates with each passing month. Ironically, our success in the pace of advancement has also become our challenge. Nearly 20 years ago, NCVHS introduced the importance of timely conversion to ICD-10 code sets (see attached timeline). With this letter, the Committee strongly urges that, if you choose to delay the scheduled implementation of the ICD-10 code sets, such delay should be decided upon and announced as soon as possible, and the delay should not be more than a year from the current deadline, recognizing the significant financial burden that accrues with each month of delay. Furthermore, we recommend that you address in the Notice of Proposed Rulemaking the following issues:

1. Use the time to identify and address the obstacles to implementation. We believe it will be important for the Department to define and establish concrete, required steps that covered entities must take between now and the implementation deadline, along the lines of the transition steps we have recommended in previous letters, to ensure a successful transition.

2. Evaluate the financial impact on the communities that are on course with preparing for implementation by the current deadline and may incur additional financial burden of maintaining two systems or stopping and restarting their preparation during a prolonged transition, as well as the financial burden borne by those who have not yet been able to begin their transition.

3. Take this opportunity of converting the ICD classification system from ICD-9-CM to the ICD 10 code sets to align this rule with the Meaningful Use Rule that specifies SNOMED CT as the standard clinical terminology for coding diagnoses on the problem list. The result would be that clinicians would document their diagnoses in the electronic health record (EHR) and their clinical terms and concepts would be converted by the EHR to SNOMED CT on the back-end. They would then have the capability of mapping SNOMED CT codes to ICD-10-CM using national standardized tools, such as the one recently developed by the National Library of Medicine (NLM) called I-Magic. This will ensure that each coding standard is used for the purpose for which it was designed, thereby helping to mitigate the ICD-10-CM user interface challenges. The NLM-developed I-Magic tool is a good example of a national, standardized user-friendly interface tool for the conversion from clinical language to these structured terminologies and classifications (SNOMED CT, ICD-10-CM).

Later this year we plan to hold hearings on the status of ICD- 10 Code Set industry planning and will be submitting to you additional recommendations on ways to achieve a successful transition to the new code set.

Sincerely,

/s/

Justine M. Carr, M.D.

Chairperson,

National Committee on Vital and Health Statistics

Cc: Data Council Co-Chairs

Enclosure Re: Possible Delay of Deadline for Implementation of ICD-10 Code Sets 3 National Committee on Vital and Health Statistics