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ICD-10 Codes Delayed Once More

Compliance with the switch to ICD-10 diagnosis coding is officially delayed to October 1, 2014. Download the full text of the final rule.

On August 24, the US Department of Health and Human Services (HHS) published a final rule announcing that it would hold off on the previously scheduled compliance date. Earlier in the year, ACP advocated the delay, recommending that HHS allow at least another year beyond 2013, for physicians, other health care professionals, developers, and vendors to fully develop and integrate the new coding set into their practices and facilities.

In its proposed rule, CMS asked the public to comment on whether the compliance date should be delayed, and if so, for how long. ACP submitted its comments to CMS, first noting the College’s standing opposition to the ICD-10 code set implementation, and then its recommendation for a one-year delay.

ACP maintains its concerns about the costs of switching to an entirely new diagnosis system, particularly for the small physician practices that are least able to absorb additional costs. However, the College’s comments state “…ACP also understands that if the Department were to rescind the law governing the transition to ICD-10, it would cause great losses to those physicians, medical practices, and facilities that have already expended financial and human resources toward implementing the new, diagnosis code set.

ACP agreed that the change in the compliance date for ICD-10, as proposed in the rule, would give clinicians and other covered entities time to prepare and test their systems to ensure a smooth and coordinated transition by all industry segments.” Despite its continued opposition to the implementation, ACP supports the Secretary’s decision to delay the ICD-10 compliance date until October 1, 2014.

CMS received many comments from the public regarding how the government should handle the code set transition. Appearing in the final rule, many of the comments having great impact are those that reflect on the transition experience from electronic claims standard Version 4010 to Version 5010. With the Version 5010 transition still fresh in memory, sentiments toward the ICD-10 transition will certainly be influenced by that experience.

From the largest parties — hospital systems, health plans, large physicians practices — CMS heard about the large investments that had already been made towards ICD-10 compliance, such as spending on new computer systems and adding personnel for the transition. From commenters of all sizes, the agency heard about the ICD-10 project timelines that had been upset by the problems with the Version 5010 transition, making it less likely that physicians and other providers could have been ready for ICD-10 by the 2013 deadline.

ACP in particular, recommended that CMS examine the idea of using Systematized Nomenclature of Medicine — Clinical Terms (SNOMED-CT), as a superior system to ICD-10 for use in performing and documenting clinical care activities.

The College believes that although it is clear that coding with a classification system such as ICD-10 has benefits for compiling data for secondary purposes, it is generally acknowledged that a reference terminology such as SNOMED-CT is much more effective for accurately capturing the nuances of health conditions and clinical care.

Unfortunately, CMS did not accept this recommendation. The agency cites the considerable financial investments that have been made towards ICD-10 compliance and the projected timelines and uncertainties that would have to be addressed were the agency to forego using ICD-10 for a different code set.

In explaining its reasons for choosing to delay implementation, CMS acknowledged the over-arching concern with an ill-timed transition: that physicians and providers who are forced to expend already-scarce resources to implement and participate in other CMS initiatives, such as electronic prescribing, Physician Quality Reporting System, meaningful use/electronic health records, accountable care organizations, patient centered medical homes, that have similar compliance timeframes would not be able to successfully transition to ICD-10.

Industry surveys showed that health care industry segments were in vastly differing states of readiness for ICD-10, as they had also been for the Version 5010 transition.

We hope that CMS and the industry learn from their collective experience with Version 5010 and better prepare for the ICD-10 transition, through product readiness, thorough end-to-end testing processes and scheduling, training, priority setting, and trading partner agreements on what needs to be accomplished.

ACP will continue to inform its members about ways to implement the new code set, through articles, seminars and workshops, and other tools.