Voices Raised Supporting and Opposing New ICD-10 Timeline
Two bills currently being considered by Congress, H.R.4157 Health Information Technology Promotion Act of 2005 (HITPA) and S.1952 Critical Access to Health Information Technology Act of 2005, call for covered entities under the Health Insurance Portability and Accountability Act to use ASC X12 and National Council for Prescription Drug Programs (NCPDP) standards for all transactions April 1, 2009 and to use ICD10-CM and PCS for transactions October 1, 2009. These bills are still in subcommittees for study and comment. There have been two separate meeting during April at which voices have been raised in both support and opposition to this timeframe.

On April 6 at the House Ways and Means Subcommittee meeting the Blue Cross Blue Shield Association (BCBSA) urged Congress to adopt a realistic timetable for the transition from ICD-9-CM to ICD-10. And on April 19-20, the Workgroup for Electronic Data Interchange (WEDI) held an ICD-10-CM and ICD-10-PCS Forum in Chicago to discuss the impact of transitioning to a new code system. A summary report and action plan is expected to be released and additional healthcare forums are to be held in the future. A cross-section of healthcare entities was represented at the forum.
Among the issues raised were the following:

involved in implementing ICD-10 concurrently with the consolidation of Medicare administrative contractors from 50 to 15 contractors
Coordination of upgrading all ten HIPAA transactions to a new 5010 version.
Analysis and refinement of backward and forward electronic crosswalks between ICD-9 and ICD-10
Training and preparation of health care professionals for the major change in their practice that will be called for by ICD-10.
Pilot testing needed to ensure the new system works, providers are educated, and claims will be paid

Testimony urged the extension of the compliance date by three years, with implementation beginning in 2010, and final compliance in 2012. Three additional years are needed because of these issues.

Testimony was also heard supporting the current proposed timeline of implementation of October 2009 due to the pressing need to overhaul the current coding system in order to keep pace with changing technology and knowledge. No final decisions have been made at this time and the discussions continue. This is the time to educate and prepare.
If you would like further information with regard to testimony provided at these forma please logon to:

Ways and Means Committee website
http://waysandmeans.house.gov/hearings.asp?formmode=view&id=4829

Or the WEDI website
http://www.wedi.org/public/articles/dis_viewArticle.cfm?ID=495

Two Steps Forward

Rep. Nancy Johnson (R-Conn.) introduced the Health Information Technology Promotion Act of 2005 (HITPA) (HR 4157) to the House of Representatives on November 4, 2005 which outlines the goals of the Office of the National Coordinator of Health Information Technology, the duties of the National Coordinator, the staffing and authorization of appropriations for the office. As reported previously, a provision with in that HITPA requires the adoption and implementation of ICD-10-CM and ICD-10-PCS by October 1, 2009. The bill was referred to the House and Ways subcommittee on Health.

On November 2, 2005, Senator Norm Coleman (R-MN) introduced the Critical Access to Health Information Technology Act of 2005 (CAHITA) (S. 1952) to the Senate and referred to the Committee on Health, Education, Labor, and Pensions. This legislation is intended to provide grants for rural health information technology development activities. Section 3 of this bill, Replacement of the International Statistical Classification of Diseases, requires the issuance of a final rule to replace ICD-9-CM with ICD-10-CM and ICD-10-PCS effective October 1, 2009.

The bill states that no later than 30 days after the date of enactment of CAHITA, the Secretary of Health and Human Services shall issue and publish in the Federal Register a Notice of Intent to adopt the Accredited Standards Committee X12 HIPAA transactions version 5010 no later than April 1, 2007, and compliance with such rule shall apply to transactions occurring on or after April 1, 2009; to adopt of the National Council for Prescription Drug Programs Telecommunications Standards version 5.1 with a new version no later than April 1, 2007, and compliance with such rule shall apply to transactions occurring on or after April 1, 2009; to adoption of ICD-10-CM and ICD-10-PCS no later than October 1, 2006, and compliance with such rules shall apply to transactions occurring on or after October 1, 2009; and covered entities and health technology vendors under the Health Insurance Portability and Accountability Act of 1996 shall begin the process of planning for and implementing the updating of the new versions and editions referred to in this subsection.

The actions by committees and subcommittees are the most important phase of the legislative process. The committees provide perform intensive research and provide opportunity for public comment. Bills are then reintroduced to the full House or Senate after acceptance of recommendations. Rulings are then made on the individual bills. The process has no specified time limitation.
Keep in mind that both these pieces of legislation must be passed by both the House and the Senate before becoming law. Ingenix will monitor the progress of this initiative and, as always, keep you informed. At this time neither code system has been adopted as a standard code set nor has an implementation date been set. However, the inclusion of the provision to issue an NPRM within these Acts indicates growing support and should renew the discussion on the issue of code set conversion.

Rep. Nancy Johnson (R-Conn.) is expected to introduce the Health Information Technology (HIT) Promotion Act of 2005 to the House of Representatives sometime this fall.

Rep Johnson is the chair of the House Ways and Means Health subcommittee and plans to introduce a bill designed to amend the Social Security Act by formally establishing the Office of the National Coordinator of Health Information Technology now headed by the National Coordinator, David J. Brailer, MD. The bill outlines the goals of the Office, the duties of the National Coordinator, the staffing and authorization of appropriations for the office. In addition, provisions address the exemption to federal anti-fraud laws to allow healthcare providers to share health information technology and training services and address the harmonization of state and federal laws governing security and confidentiality of individually identifiable health information.

Most importantly, there is also a provision within the HIT Promotion Act of 2005 draft that addresses rule making for the adoption of updated ICD codes under HIPAA standards and Medicare. Within 90 days of adoption of the Act, the Secretary of HHS must issue a notice of proposed rule making (NPRM) replacing ICD-9-CM with ICD-10-CM and ICD-10-PCS. The rule will apply to all transactions occurring on or after October 1, 2008. A move toward the ICD-10-CM and ICD-10-PCS coding systems would provide more accurate data that is better suited to electronic health records. Achieving the goals of an internet-based nationwide health information network and interoperable electronic health record adoption across health care providers would also benefit from the adoption of a new standard code system.

Keep in mind that this Health Information Technology Promotion Act of 2005 would have to be passed by both the House and the Senate before becoming law. Ingenix will monitor the progress of this initiative and, as always, keep you informed. At this time neither code system has been adopted as a standard code set nor has an implementation date been set. However, the inclusion of the provision to issue an NPRM within this Act indicates growing support and should renew the discussion on the issue of code set conversion.

Morphology Code and ICD-10-CM
The new coding scenario for ICD-10-CM, a case study of intramural and submucous leiomyoma, includes instruction about assigning morphology codes with neoplasm codes in ICD-10-CM. The ICD-9-CM classification system includes Appendix A: Morphology of Neoplasm. Morphology codes are a classification of neoplasms according to tissue type or cell origin. The Alphabetic Index of Disease in ICD-9-CM lists the morphology code after the main term entry for the neoplasm along with the behavior code (/0-6). For example: Choriocarcinoma (M9100/3), M9100/3 is choriocarcinoma a trophoblastic neoplasm, malignant, primary site. The coding guidelines for ICD-9-CM do not require the use of morphology codes in reporting. The appendix has been used primarily as reference.

To what system do these morphology codes belong? Why are they expected to be an integral part of ICD-10-CM? A brief history of the development of morphology codes follows.

In 1976, WHO published the first edition of the International Classification of Diseases for Oncology, which had a topography section based on the malignant neoplasm classification in ICD-9 and coded nomenclature for the morphology of neoplasms. This coded nomenclature is what is represented in Appendix A of ICD-9-CM.

The Second Edition of the International Classification of Disease for Oncology was a dual classification and coding system for both topography and morphology. The topography code uses the same three- and four-character categories as ICD-10 for malignant neoplasms (C00-C80), allowing greater specificity for the site of non-malignant neoplasms than is possible in ICD-10. The Second Edition of ICD-O has been used extensively throughout the world.

The third edition of ICD-O (ICD-O-3) was developed by a working party convened by WHO. The morphology codes for neoplasms have been revised, especially for lymphomas and leukemias. ICD-O-3 was intended to be used in cancer registries throughout the world beginning with cancers diagnosed on January 1, 2001 and forward. However, several countries that have decided to delay implementation of ICD-O-3 due to the many changes incorporated in ICD-O-3.

The morphology codes have not been included as an official supplement or appendix to ICD-10-CM. The official guidelines do indicate that we will indeed be using morphology codes under ICD-10-CM.

2.3 Morphology codes
Though the Neoplasm Table provides codes based on the histologic type, it only distinguishes between in-situ, benign, malignant or "of uncertain behavior." A secondary morphology code is needed to specifically identify the histologic type of the tumor. A morphology code should be included on a medical record that has a neoplasm diagnosis whenever possible. The morphology codes are found in a separate section of the classification. The proper morphology code can be located in the Index under the term for the histology of the neoplasm.

The separate section mentioned in the guidelines has not been posted. Be prepared by becoming more familiar with the morphology code information found in ICD-9-CM.