Does an 18-Month “coding-accuracy delay” help individual patients, clinicians, or the taxpayer?

The H.R. 2247 bill containing a “coding-accuracy delay”, known as “safe harbor” introduced by Rep. Diane Black has myriad effects, both short term and long term, to our healthcare system.

It is not plausible to think a Healthcare Provider would miscode a medical condition. The more likely scenario is the use of unspecified diagnosis codes, which appear on the surface to have little financial impact. However, the use of unspecified diagnosis codes has long lasting effects on multiple functions within the healthcare domain. Both of these points should be taken seriously.

There is no financial impact to the professional provider who submits claims with CPT, HCPCS, etc. codes using the new ICD-10 diagnosis codes. The use of unspecified diagnosis codes does not affect their payment but has lasting consequences to other functions within the healthcare system.

ICD-10 codes do have a direct impact to the institutional claim, as both diagnosis and procedure codes are utilized for payment. How is the institutional provider incentivized to submit unspecified or inaccurate diagnosis when the “less specific or unknown” diagnosis yields less payment?

Misuse of an “unspecified” diagnosis or a less-specific diagnosis has immediate and lasting implications.

Clinical Consequences—

• Restricts clinicians’ knowledge to the “real medical condition” which could impact future healthcare delivery

• Delays access to meaningful healthcare data

• Skews outcomes that are data dependent

Operational Inefficiencies—

• Waste resources (coding, revenue) – introduces errors into delivery model

• Introduces inefficiencies into the healthcare system

Data integrity compromised —

• The diagnosis code “links” the patient and the data across the healthcare continuum

• Diagnosis codes identify “what isn’t present” as well as “what is present”

• Decreases effective engagement of all stakeholders in delivering healthcare

Diagnosing is the Epic of Healthcare Delivery. Once again, it appears that the individual patient is the loser in a world utilizing “creativity” to benefit the few. Ultimately, more obstacles cost all of us money – our tax dollars poorly utilized.

H.R. 2247 – ICD-TEN Act

(b) Safe harbor.—During the implementation period described in subsection (a), no claim submitted for payment under title XVIII of the Social Security Act by a health care provider pursuant to the ICD–10 standard medical data code sets shall be denied due solely to the use of an unspecified or inaccurate subcode.