Urology Practice Management - April 2015, Vol 4, No 2 - Coding and Billing
Ellen Martin

The American Urological Association (AUA) is continuing to put pressure on the US government to postpone an imminent transition to the International Classification of Diseases, Tenth Revision (ICD-10) until more practices have time to adjust to the new set of billing codes. In his testimony to a US House of Representatives subcommittee as a member of the AUA, William J. Terry, Sr, MD, outlined the organization’s concerns with ICD-10 implementation.

Released earlier this year, the transcript of Dr Terry’s testimony in February demonstrates the association’s concerns with an implementation date for the new codes of October 1, 2015, including increased administrative and financial burdens that urology practices may incur.

“I hope that you will keep in mind the concerns of practicing physicians—particularly those in small practices—balanced with proven advantages of ICD-10 on direct patient care and weighed against the consequences of a poorly executed implementation,” Dr Terry said in his testimony. “This is what I always discuss with my patients when sharing in the decision on various treatment options; ‘Do the benefits outweigh the risks?’ ”

The association is also asking the Centers for Medicare & Medicaid Services (CMS) to release the results of testing it has done on some practices in order to shed light on the ease or difficulty of using ICD-10.

“We urge CMS to release the details of its end-to-end testing, as well as its contingency plans should providers not be prepared on October 1, 2015. We urge Congress to delay implementation of the ICD-10 code set and appoint a committee to better study the ‘risks and benefits,’ ” Dr Terry stated, according to a summary of his testimony.

In the summary, he said that if a delay is impossible, Congress should consider legislating a period during which physicians can use ICD-10 or keep using ICD-9. Similar sentiments were voiced in a March 2015 letter to CMS Acting Administrator Andrew Slavitt from the AUA and more than 50 other national medical associations, including the American Medical Association, as well as 47 state medical associations. They stated that the ICD-10 transition is “one of the largest technical, operational, and business implementations in the healthcare industry in the past several decades.” The signatory organizations urged the following:

  • Because only 89% of claims were accepted in the March 2014 end-to-end test and 76% in the November 2014 test, and the number of practices tested was very small, CMS should release more detailed end-to-end testing results, including the type and size of providers who tested use of ICD-10, the number of claims tested by each practice, the percentage of claims processed successfully, details about problems that occurred, and what steps need to be taken to correct the problems
  • The Physician Quality Reporting System and Meaningful Use quality reporting periods straddle October 1, and CMS has not discussed how it plans to address the reporting of these metrics after the transition to ICD-10. The organizations urged CMS to clarify how it plans to ensure that the measure calculations for these programs are not adversely impacted by the transition, ensure that crosswalks do not attribute increased costs to a physician’s Value-Based Modifier score when switching to ICD-10, and that the changes in measure specifications will be stable and budget-neutral for providers
  • CMS should commit to providing advance payments to physicians who are experiencing a severe financial hardship as a result of the change to ICD-10, particularly if the issue originates on Medicare’s end, and should work with the Office of the National Coordinator for Health Information Technology to provide information about electronic health record–vendor readiness for ICD-10 codes
  • CMS should ensure that it will not audit claims simply for code specificity.

The actual financial cost for practices to implement ICD-10 has been a source of study and debate. An article published in the Journal of the American Health Information Management Association pegged the cost of implementation for small practices at $1960 to $5900.1 A paper released in February 2014 that was prepared by Nachimson Advisors for the American Medical Association, however, suggested a range of costs to providers depending on the size of the practice: $56,639 to $226,105 for a small group practice (3 providers, 2 administrators); $213,364 to $824,735 for a medium group practice (10 providers, 1 coder, 6 administrators); and $2 million to $8 million for a large group practice (100 providers, 64 coding staff). This 2014 report was an update of a study on the same topic that Nachimson Advisors first released in 2008.2,3

Dr Terry said that physicians are resigned to implementation of ICD-10 but hope that CMS will put in place measures to mitigate some of the potentially devastating effects on healthcare practices. Jonathan Rubenstein, MD, Director of Coding and Compliance with Chesapeake Urology, Baltimore, MD, and a member of the AUA Coding & Reimbursement Committee, echoed some of Dr Terry’s concerns, and noted that the AUA will work hard to help its members prepare for this transition.

“While there is controversy on the exact financial burden this will place on providers and practices, we know the burden will be great,” Dr Rubenstein said. “The AUA will continue to support its members and assist them in their preparations for this transition to ICD-10.”
CMS declined to comment for this story.


  1. Kravis TC, Belley S, Smith DM, Averill RF. Cost of converting small physician offices to ICD-10 much lower than previously reported. J AHIMA website. Published November 12, 2014. Accessed April 2, 2014.
  2. Nachimson Advisors, LLC. The cost of implementing ICD-10 for physician practices – updating the 2008 Nachimson Advisors Study. A report to the American Medical Association. February 12, 2014.
  3. The impact of implementing ICD-10 on physician practices and clinical laboratories: a report to the ICD-10 coalition. Nachimson Advisors, LLC. Nachimson Advisors website. Published October 8, 2008. Accessed April 2, 2015.
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