Privacy Impacts of ICD-10 and 5010?

Haven't heard much about this, but I did do an audiocast last month (see Dennis Melamed's Audiocast Site) which discussed the increased amount of information ICD-10 will include, and the impact on privacy. With more specificity in the diagnosis, we have increased information in the hands of the health plans. Do staff who currently deal with diagnoses codes need all that information? What about the customer service folks?

Also impacts on the "de-identification" issue. Since we have more codes, we will have smaller cells when summarizing results by diagnosis codes. Will some of the cells be too small?

An example of the increased specificity and the implications. Now, we have one sports injury code. Under ICD-10-CM, there are 24 codes for injury, broken down by the sport and the type of injury. All of a sudden, we will be getting statiistics on injury by sport. Who needs to know this, and should it be kept from certain eyes. Don't know, but what if the "anti-lacrosse" folks get a hold of data showing more injuries in lacrosse than in other sports. Do they try and get lacrosse banned?

This is an innocuous example, but it gets more serious as we look at more serious diseases.

Rush to Publish Regs?

There was a story yesterday about the administration’s rush to publish final rules. See http://www.msnbc.msn.com/id/27312289/ ... While this is an Interior Department rule, I would guess that HHS is looking to get out the final rules on ICD-10 and 5010/D.0 before the end of the year.

The major concern with this is that they will not adequately address public comments, and will rush out something that is unworkable. Hopefully, our friends in Baltimore and Washington will do their best to create a workable solution.

You can see the public comments on the NPRMs at http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=CMS-2008-0101 for the X12/NCPCP rule and http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=CMS-2008-0096 for the ICD-10 rule.


Let’s watch and see what CMS does.