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If you’re a healthcare professional not living under the proverbial rock, you most likely already are aware that the U.S. Department of Health and Human Services (HHS) has provided some guidance on the much-anticipated revised ICD-10 implementation date.

After creating substantial unrest and speculation in February (when HHS announced that it was considering extending the implementation date, but gave no specifics), HHS on April 9 announced a proposed rule to extend the compliance date from Oct. 1, 2013 to Oct. 1, 2014.

The announcement was part of an overall proposed rule that includes establishing a unique health plan identifier to smooth electronic data interchange under HIPAA. The ruling currently is under a 30-day comment period.

We serve a number of payer and provider clients, and in general, we are seeing positive reaction from most of our client base. Some observations:

  • Virtually all of our clients are expressing relief at finally having some guidance after a couple months of angst. It has been very difficult for them to keep focus and maintain momentum in their ICD-10 program teams in the face of a potentially lengthier delay.
  • Most of our clients are pleased that the extension is only one year. A longer duration most likely would have caused a significant pause in their ICD-10 programs, whereas a one-year delay allows them to maintain continuity (albeit with a slower “burn rate” for many).
  • Our payer clients are pleased that staggered compliance dates by entity type (payers, institutional providers, practice groups, small offices, etc.) were not proposed. Due to HHS’s wording of postponing for “certain healthcare entities,” there has been much speculation about which entities would need to be ICD-10-compliant, and by when. For payers, a staggered implementation would be a nightmare in many process areas. Some of our provider clients don’t share this line of thought, however, and would have been tolerant of a staggered implementation.
  • Our “laggard” clients (mostly providers and small payers) feel that the extension allows them to instantly go from being behind to believing that they now can meet the mandated date with no serious issues (although the “super laggards” – you know who you are – are grousing that a two-year extension would have been better).
  • Our “leader” clients (mostly large and mid-size payers) are feeling more confident in their ability to make ICD-10 transition a success. Although these clients were confident in their ability to be prepared internally to begin with, they were heretofore concerned that their trading partners would not really be ready, meaning they could not test their remediated processes and systems adequately.

There is still some lingering angst. This was not the first postponement of ICD-10 implementation, and with a couple of “grace periods” for HIPAA 5010, many of our clients are skeptical as to HHS’s ability to really stick to (and enforce) mandate dates.

About the Author

John Wollman is the Executive Vice President of Healthcare for HighPoint Solutions, a Management and Information Technology consulting firm focused on Healthcare and Life Sciences.  John is responsible for HighPoint’s Healthcare industry group, catering to Payers and Providers.  John is a recognized expert in several healthcare business domains (Reform, HIPAA 5010, ICD-10, Platform Strategy) and technical domains (Master Data Management, Analytics).  Since graduating from Duke University, John has held executive level positions at consulting and technology companies over his 25 years in business.

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