The forced implementation of ICD-10-CM (International Classification of Diseases, Tenth
Revision, Clinical Modification) codes that are specific to the United States, scheduled
for implementation October 1, 2015, which is vastly different from ICD-10 (International
Classification of Diseases, Tenth Revision), implemented worldwide, which has 14,400
codes, compared to ICD-10-CM with 144,000 codes to be implemented in the United
States is a major concern to practicing U.S. physicians and a bonanza for health IT and
hospital industry. This implementation is based on a liberal interpretation of the Health
Insurance Portability and Accountability Act (HIPAA), which requires an update to ICD-9-
CM (International Classification of Diseases, Ninth Revision, Clinical Modification) and
says nothing about ICD-10 or beyond. On June 29, 2015, the Supreme Court ruled that
the Environmental Protection Agency unreasonably interpreted the Clean Air Act when it
decided to set limits on the emissions of toxic pollutants from power plants, without first
considering the costs on the industry. Thus, to do so is applicable to the medical industry
with the Centers for Medicare and Medicaid Services (CMS) unreasonably interpreting HIPAA
and imposing existent extensive regulations without considering the cost.
In the United States, ICD-10-CM with a 10-fold increase in the number of codes has resulted
in a system which has become so complicated that it no longer compares with any other
country. Moreover, most WHO members use the ICD-10 system (not ICD-10-CM) only to
record mortality in 138 countries or morbidity in 99 countries. Currently, only 10 countries
employ ICD-10 (not ICD-10-CM) in the reimbursement process, 6 of which have a single
payer health care system.
Development of ICD-10-CM is managed by 4 non-physician groups, known as cooperating
parties. They include the Centers for Disease Control and Prevention (CDC), CMS, the
American Hospital Association (AHA), and the American Health Information Management
Association (AHIMA). The AHIMA has taken the lead with the AHA just behind, both with
escalating profits and influence, essentially creating a statutory monopoly for their own
benefit. Further, the ICD-10-CM coalition includes 3M which will boost its revenues and
profits substantially with its implementation and Blue Cross Blue Shield which has its own
agenda. Physician groups are not a party to these cooperating parties or coalitions, having
only a peripheral involvement.
ICD-10-CM creates numerous deficiencies with 500 codes that are more specific in ICD-9-CM
than ICD-10-CM. The costs of an implementation are enormous, along with maintenance
costs, productivity, and cash disruptions.
Key words: ICD-10-CM, ICD-10, ICD-9-CM (International Classification of Diseases, 10th
Revision, Ninth revision, Clinical Modification), Health Insurance Portability and Accountability
Act (HIPAA), Health Information Technology (HIT), costs of implementation
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