I feel like the fog is beginning to lift with the resignation of Kathleen Sebelius as head of Health and Human Services. It has become more obvious to me why the ICD-10 delay did not get killed in the Senate and why the President did not execute his veto power.

With the voice of the American Medical Association (AMA) and other organizations against I-10 and the potential for high risk challenges, one might suspect that there is political strategy to ward off a storm of risk and potential chaos, which industry surveys have supported in the last few months.

One can now ask the obvious question: What is the next step? Do you stay the course, or do you build a strategy to survive the impending storm?

I took the pulse by doing an informal survey of several Industry organizations. It appears that the segment of the industry that has been progressing down the path towards a 2014 compliance date are staying the course with a possible greater collaboration with trading partners. But one might wonder, if the budgets are reallocated as organizations begin the 2015-2016 budget cycles, what the risk and business challenges to I-10 might be? One can only assume that if budgets are reduced or ICD-line items eliminated from the budget, it might move organizations from staying the course to surviving the storm.

We once called ICD-10 “The Perfect Storm;” I would argue that many of the signs are falling into place for the storm to transform into a swirling tornado. The Perfect Storm has increased in volume, with quotes like that in MedPage: “With elections looming in November, organized medicine will likely have to start anew with its lobbying efforts under a new Congress next year.” Physician groups—although they oppose the sustainable growth rate (SGR) patch—have been pushing for help on ICD-10, which they received.

So the storm is beginning to rage: Delays in regulatory compliance deadlines, changes with HHS, AMA and other physician groups seeking congressional help, a general election in 2014 and a national election in 2016, and a louder cry for repeal of ACA. Equally important is the strength of the healthcare lobbyist during the election cycle, whether the ICD-10 delay might be a chess piece on the election chessboard or a bargaining chip. We need a loud resounding voice of action, rather than reaction!

How does one survive? I would suggest that we stay the course and transition to ICD-10, as behind ICD-10 is ICD-11, and if one looks to WHO for the value proposition of ICD-11 it sounds very much like the potential benefits to be realized by the implementation of ICD-10.

The World Health Organization (WHO) has revised the objective beyond mobility and mortality and value of ICD to read the following:

“The ICD defines the universe of diseases, disorders, injuries, and other related health conditions. These entities are listed in a comprehensive way so that everything is covered. It organizes information into standard groupings of diseases, which allows for:

  • easy storage, retrieval, and analysis of health information for evidenced-based decision-making;

  • sharing and comparing health information between hospitals, regions, settings, and countries; and

  • Data comparisons in the same location across different time periods.

It is the diagnostic classification standard for all clinical and research purposes. These include monitoring of the incidence and prevalence of diseases, observing reimbursements and resource allocation trends, and keeping track of safety and quality guidelines.

ICD allows the counting of deaths as well as diseases, injuries, symptoms, reasons for encounter, factors that influence health status, and external causes of disease. “

ICD-10 was endorsed in May 1990 by the Forty-third World Health Assembly. It is cited in more than 20,000 scientific articles and used by more than 100 countries around the world (117).

The US Healthcare Industry needs to accept that I-10 is interwoven into the global healthcare industry fiber. The industry is moving quickly towards a more analytically driven healthcare that mandates data standardization; ICD-9 will not provide any standardization in the era of genomics, care coordination, predictive modeling, and value-based medicine.

It is important that we have a voice in Washington, D.C., with elected officials during this next year. We cannot, as an industry, sit and wait to see what is going to happen and then raise our voices in objection! We need to also beware of the power of the lobbyist and interject an industry voice. There are 2,400 registered healthcare lobbyists and almost $500 million spent by healthcare lobbyists in 2012 and 2013. Five of the top ten lobbyists in Washington in 2013 were healthcare organizations: GE, American Hospital Association, BCBS, AMA, and Pharmaceutical Research & Manufacturers of America.


Total for Health: $480,463,898
Total Number of Clients Reported: 1,294
Total Number of Lobbyists Reported: 2,901
Total Number of Revolvers: 1,411 (48.6%)
Campaign Contributions from this sector


Total spending

Pharmaceuticals/Health Products


Hospitals/Nursing Homes


Health Professionals


Health Services/HMOs


Misc Health


NOTE: All lobbying expenditures on this page come from the Senate Office of Public Records. Data for the most recent year was downloaded on March 31, 2014. Referencehttp://www.opensecrets.org/

As an Industry we must survive the impending storm. We cannot go back; we must plan our way through the changes.

I have outlined a few steps to help survive the storm and refocus your organizational roadmap:

  • First, relax, take a deep breath! Change worth fighting for is always uncomfortable.

  • It is critical to take this time to refocus away from I-9 to I-10 code translation in an effort of benefit realization and risk mitigation.

  • Be vigilant for future landmines. Get connected within your state healthcare agencies and elected officials to have a voice. Know the lobbyists that have the strongest influence with your elected officials.

  • Become a participant in healthcare change rather than a bystander. Have a voice! Action is more positive than reaction.

  • Seek alternative solutions, compromise and collaboration; build bridges.

  • Conserving energy, resources, and budgets will be important over the next 12 to 18 months; I-10 fatigue is a reality at all levels.

  • Get a readiness pulse of ALL your trading partners. Build a consensus on how to bridge the chasm to success.

  • Don’t try to “boil the ocean.” Look to problem-solving within your region or community.

  • Don’t wander around seeking advice from multiple sources; you will get multiple answers. Spend this year building a community of practice for ICD—clinical documentation standards based on what is important for your community.

  • Remove the silos, as they have proven to be obstacle to successful compliance.

The storm will pass; the survivors will reap the benefits of having a comprehensive strategy and redesigned roadmap for the next 12 months. Rather than reacting, plan!

About the Author

Ellen VanBuskirk, senior principal in business consulting for Infosys Public Services, is a healthcare consultant focused on compliance strategies with a mission to work across the Healthcare value stream to meet regulatory challenges. VanBuskirk has conducted business development efforts in support of healthcare compliance and reform, as well as ICD-10 transformation by both provider & payer organizations. With more than 20 years of success in leading business teams and identifying emerging opportunities and challenges in the healthcare industry, VanBuskirk brings deep expertise in health plan regulatory and compliance initiatives, including healthcare reform, ICD-10 transformation, meaningful use, HITECH and HIE.

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