ICD-10 Survey: Procrastination Rules

A recent survey from the Workgroup for Electronic Data Interchange (WEDI) shows that provider readiness progress towards ICD-10 has stalled due to the government delay of the deadline for implementing the updated diagnosis and insurance codes. In March, Congress pushed the deadline from October 1, 2014 to October 1, 2015.

This latest survey shows the same percentage of providers as having completed an impact assessment as reported in October of 2013 -- meaning no progress has been made.

WEDI seems surprised that health plan testing has slipped a bit and appears to be scheduled into 2015. But if the providers are not testing, who does WEDI think the health plans would be testing with instead?

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I am surprised that WEDI is surprised. It's human nature to put off unpleasant tasks -- that's why many post offices stay open until midnight on April 15th and stores stay open late on December 24th. Online retail stores offer next-day shipping at a premium because there's a demand for it. If they didn't cater to people who procrastinate, those shoppers would go to a site that does or shop at a store that is open late. Procrastination is to be expected. There are posters that proclaim, "If it weren't for the last minute, nothing would get done."

Even Congress is not immune to the seduction of procrastination. The delay for ICD-10 itself was part of a last-minute attempt to continue the provider payment schedule. People want to delay the disruption that comes with tackling a major change such as the transition to ICD-10 for as long as possible, and the government's delay gives providers a ticket to ride for free for 12 months.

The survey results tell me that providers have put the brakes on their efforts and are working on other priorities right now. More than half of larger providers have begun external testing, while less than half of smaller providers did not expect to begin testing until 2015 or did not know when they would be testing.

This is understandable. Larger organizations have more resources and are better able to cover more than one major initiative at a time, while smaller organizations must sometimes depend on a single person to get things done. Given the delay, smaller organizations are more likely to breathe a sigh of relief and focus on more pressing issues -- like fixing claim issues so providers can get paid -- and put off dealing with regulations until they have absolutely no choice, for example, when delays will impact revenue.

Priorities must be set, and getting paid trumps getting a head start on meeting a regulation that has been delayed repeatedly. Progress reported in the latest survey likely happened before the government-imposed delay was announced, or was in process when the delay was announced and was completed before resources were diverted to other tasks.

My organization has just started to ramp up again, but with nowhere near the effort and manpower that was thrown at the initiative last year. No one is saying we have dedicated resources this time. There isn't the feeling that the budget is pre-approved. We are down many resources, having let go a number of consultants who were working on ICD-10 projects. Those resources have gone to other organizations and will not be returning to us. Resources that have stayed are working on other projects and will need to split their time between the current tasks and getting ICD-10 back on track. We will need to rebuild project teams and get back to working on unfinished ICD-10 tasks.

The government may have thought they were giving us another year to prepare, but what is actually happening could have been predicted by anyone who has taken Psychology 101: Out of sight, out of mind. Did WEDI really expect that the extra 12 months would be stuffed with ICD-10-related tasks? Hasn't anyone in that organization ever put off an unpleasant task?

ICD-10 has been delayed more than once: In January 2009 the deadline was moved from October 1, 2011 to October 1, 2013. Then it was moved to October 1, 2014. The Centers for Medicare and Medicaid Services (CMS) announced that the deadline would not change again, reiterating that statement at every webinar and presentation they held.

Then it was delayed to October 1, 2015. Anyone would be forgiven for thinking this isn't the last delay we're going to see, regardless of what the CMS says.

Here's another adage that applies: Fool me once, shame on you; fool me twice, shame on me.

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