Trouble with timelines (2) Might APA hold back DSM-5 in response to an October 2014 ICD-10-CM compliance date?

Trouble with timelines (2): Might APA hold back publication of DSM-5 in response to a firm October 2014 ICD-10-CM compliance date?

Post #200 Shortlink: http://wp.me/pKrrB-2sW

Update at August 17: Commentary on DSM-5 from One Boring Old Man: didn’t need to happen…

Update at August 16: Commentary on DSM-5 from One Boring Old Man: all quiet on the western front…

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In Trouble with timelines (1): DSM-5, ICD-10-CM, ICD-11 and ICD-11-CM, on August 10, I wrote

With no changes to the published Timeline and no intimation of further delays, I’m assuming DSM-5 remains on target.

But it’s not necessarily a given that DSM-5 will be on the bookshelves for May 2013.

Roger Peele, M.D., D.L.F.A.P.A, has been a member of the DSM-5 Task Force since 2006. From 2007- 2010, Dr Peele was APA Trustee-At-Large; since 2010, Secretary to the APA Board of Trustees.

Dr Peele maintains a website at http://rogerpeele.com/index.asp providing clinical information for Montgomery County clinicians, resources for County residents and listing some of the initiatives taken relative to the American Psychiatric Association:

http://rogerpeele.com/

Writing just a few days after HHS Secretary’s announcement of intent to postpone the compliance date for adoption of ICD-10-CM/PCS codes sets for a further year, to October 1, 2014, Dr Peele informed his readers that the proposal to delay the compliance deadline

“…reduces some of the pressures to publish DSM-5 in 2013.”

In his post of February 23, Dr Peele goes on to say that a more certain answer was expected on February 28, but that remarks at the previous day’s American College of Psychiatrists meeting suggested the timing of DSM-5 for early 2013 was still on.

This suggests to me that if HHS decides not to take forward its proposal to delay ICD-10-CM compliance until October 1, 2014 but to stick with the original compliance date of October 1, 2013, that APA will still want to get its manual out several months ahead of the ICD-10-CM compliance deadline.

In order to meet a publication date of May 2013, APA says the final manual text will need to be with the publishers by December, this year. So unless HHS announces a decision within the next few weeks, APA isn’t going to have very much time left in which to dither over potentially shifting publication to 2014.

ICD-10-CM will be freely available online and is already accessible for pre implementation viewing. It’s the policy of WHO, Geneva, to make print versions of ICD publications globally available at reasonable cost. Although ICD-10-CM has been developed by US committees for US specific use, it’s not expected that print versions of ICD-10-CM will be as expensive as DSM-5.

DSM manuals are expensive; they are a commercial product generating substantial income for the APA’s publishing arm. APA will be looking to maximize sales and publication revenue and retain market share with this forthcoming edition.

There are already groups and petitions calling for the boycotting of DSM-5 in favour of using Chapter 5 of ICD-10-CM, when its code sets are operationalized.

So if ICD-10-CM is to be adopted by October 1, 2013, I cannot see APA and American Psychiatric Publishing not aiming to steal a march.

If, on the other hand, HHS were to announce shortly a firm rule that compliance for ICD-10-CM is being pushed back to October 2014, if DSM-5 Task Force and work groups are struggling to finalize the manual or having problems obtaining approval for some of their more contentious proposals from the various panels that are scrutinizing the near final draft, then delaying publication of DSM-5 to late 2013 or spring 2014 would provide APA with a window in which to complete its manual but still push it out ahead of ICD-10-CM.

Its PR firm can sell a publication delay to end-users as the APA’s taking the opportunity of postponement of ICD-10-CM compliance to allow more time for evaluation of DSM-5 field trial results, refinement of criteria or honing disorder description texts, and that a delay will better facilitate harmonization efforts with ICD-10-CM and ICD-11.

(ICD-10-CM is a modification of the WHO’s ICD-10 and has closer correspondence with DSM-IV than with DSM-5. Since 2003, ICD-9-CM diagnostic codes have been mandated by HIPAA for all electronic reporting and transactions for third-party billing and reimbursement and DSM-5 codes will need to be crosswalked to ICD-9-CM codes, for the remaining life of the ICD-9-CM. DSM-5 codes will also need to be convertible to ICD-10-CM codes for all electronic transactions.)

In a June 2011 presentation to the International Congress of the Royal College of Psychiatrists, APA President, John M. Oldham, MD, MS, spoke of “Negotiations in progress to ‘harmonize’ DSM-5 with ICD-11 and to ‘retro-fit’ these codes into ICD-10-CM” and that DSM-5 would need “to include ICD-10-CM ‘F-codes’ in order to process all insurance claims beginning October 1, 2011.”

With the drafting timelines for the three systems now so out of whack and a partial code freeze on ICD-10-CM, and with ICD-11 still at the Beta drafting stage, I can no longer be bothered to attempt to unscramble how alignment of the three systems [or best fit where no corresponding category exists] is going to dovetail, in practice, pre and post publication, or what the implications might be for the medical billing and coding industry, for clinicians and for patients.

Dr Peele then says

“Since ICD-11-CM is due in 2016, it may become appealing to the Feds to skip ICD-10-CM, and wait until 2016”

ICD-11-CM due in 2016?

Not so. It is the WHO’s ICD-11 that is aiming for readiness by 2016.

A misconception on the part of Dr Peele or wishful thinking?

It might suit the interests of APA and American Psychiatric Publishing, financially and politically, if ICD-10-CM were to be thrown overboard and instead, the US skip to a Clinical Modification of ICD-11, two or three years after a copy of its shiny new DSM-5 is sitting on every psychiatrist’s desk.

But that is not going to happen in 2016.

There is strong federal opposition, in any case, against leapfrogging over ICD-10-CM to a US modification of ICD-11:

Federal Register, January 16, 2009:

…We [ICD-9-CM Coordination and Maintenance Committee] discussed waiting to adopt the ICD-11 code set in the August 22, 2008 proposed rule (73 FR 49805)…

…However, work cannot begin on developing the necessary U.S. clinical modification to the ICD–11 diagnosis codes or the ICD–11 companion procedure codes until ICD–11 is officially released. Development and testing of a clinical modification to ICD–11 to make it usable in the United States will take an estimated additional 5 to 6 years. We estimated that the earliest projected date to begin rulemaking for implementation of a U.S. clinical modification of ICD–11 would be the year 2020.

The suggestion that we wait and adopt ICD–11 instead of ICD–10–CM and ICD–10–PCS does not consider that the alpha-numeric structural format of ICD–11 is based on that of ICD–10, making a transition directly from ICD–9 to ICD–11 more complex and potentially more costly. Nor would waiting until we could adopt ICD–11 in place of the adopted standards address the more pressing problem of running out of space in ICD–9–CM Volume 3 to accommodate new procedure codes…

And from a more recent Federal Register document:

Federal Register, April 17, 2012:

3. Option 3: Forgo ICD-10 and Wait for ICD-11

…The option of foregoing a transition from ICD-9 to ICD-10, and instead waiting for ICD-11, was another alternative that was considered. This option was eliminated from consideration because the World Health Organization, which creates the basic version of the medical code set from which all countries create their own specialized versions, is not expected to release the basic ICD-11 medical code set until 2015 at the earliest.

From the time of that release, subject matter experts state that the transition from ICD-9 directly to ICD-11 would be more difficult for industry and it would take anywhere from 5 to 7 years for the United States to develop its own ICD-11 CM and ICD-11-PCS versions.

From an interview with Christopher Chute, MD, Making the Case for the ICD-10 Compliance Delay April 4, 2012, by Gabriel Perna for Healthcare Informatics:

“…Chute is also adamant that there is no possible reason or possibility that the U.S. could just skip over ICD-10 right into ICD-11. Even with his ties to ICD-11, Chute says there it’s not realistic, nor is it plausible, to have seven-to-nine more years of ICD-9 codes, while the medical industry waits for the World Health Organization to finish drafting ICD-11 and then waits for the U.S. to adapt it for its own use.”

A recent article in the JOURNAL OF AHIMA/July 2012/Volume 83, Number 7 in response to Chute et al [1] suggests the earliest the US could move onto a CM of ICD-11 might be 2025, or 13 years from now.

So, if HHS were to announce, soonish, a final rule for an October 1, 2014 ICD-10-CM compliance date, it’s not totally out of the question, in my view, that APA (who might be struggling to complete the manual for December) may extend its publication date for a second time.

References

1] There are important reasons for delaying implementation of the new ICD-10 coding system. Chute CG, Huff SM, Ferguson JA, Walker JM, Halamka JD. Health Aff (Millwood). 2012 Apr;31(4):836-42. Epub 2012 Mar 21 http://www.ncbi.nlm.nih.gov/pubmed/22442180  (Abstract free; Subscription or payment required for full text)