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