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On Monday, April 9, the U.S. Department of Health and Human Services (HHS) issued proposed rule CMS-0040-P, in which it proposed a one-year delay for implementing ICD-10-CM/PCS.  This proposal would extend the ICD-10 compliance date to Oct. 1, 2014 and also mandates a 30-day public-comment period prior to issuance of a final rule. The delay was instigated by the American Medical Association (AMA) and other provider groups in late 2011, and HHS announced its intent to delay in February 2012. The concern among these groups primarily centered on provider readiness and ability to meet the original compliance mandate of Oct. 1, 2013. This concern was exacerbated in part by ongoing work toward achieving 5010 compliance, as well as the cost associated with implementing ICD-10.

There has been much industry speculation regarding the implementation deadline for ICD-10, and while it is a relief that The Centers for Medicare & Medicaid Services (CMS) has released the revised compliance date, no doubt many will be left asking, “Where do we go from here?” Hundreds of millions of dollars are at stake, and while the industry has been given additional time, we are still less than 900 days from the revised implementation date. This is not a lot of time, and it certainly does not justify halting or slowing down work being done for ICD-10 compliance. Many organizations wisely have pushed forward with such work despite the announced delay. Momentum is a critical issue in light of this development.

Continuing forward momentum certainly has been challenging given coverage in the press and the nearly impenetrable shroud of silence that had been cloaking CMS regarding ICD-10. This scenario created the perfect Petri dish for rumor and speculation to take hold across the industry. It seemed that every day there had been new theories and speculative commentary as to what could happen. While the proposed rule is good news, it is certain that the commentary period will be used by industry stakeholders to provide strong guidance to CMS regarding the steps needed to implement ICD-10 successfully.

One positive note in the HHS Fact Sheet stated that “all covered entities must transition to ICD-10 at the same time to ensure a smooth transition to the updated medical data code sets. Failure of any one industry segment to achieve compliance with ICD-10 would negatively impact all other industry segments and result in rejected claims and provider payment delays.” This is a welcome perspective considering some of the recent speculation amid the private sector that there might be some sort of fragmentation in implementing the code sets as a result of the delay.

For those organizations wondering about next steps, it’s simple: keep moving forward. ICD-10 is not going away, and it is unlikely that the public commentary period will change the proposed compliance date in any meaningful way. Hopefully, the commentary period will give industry stakeholders a voice to help guide CMS as they make suggestions regarding implementation, particularly in the area of testing.

A one-year delay could be a gift, provided that momentum is not slowed. The proposed delay will enable better, more thorough testing programs and better management of the change processes required to implement ICD-10.  Now that we have some clarity, it hopefully also will clear up much of the speculation and uncertainty regarding ICD-10 and bring a renewed sense of urgency and stability back to the marketplace. The old mantra still remains: keep calm and carry on, ICD-10 is coming!

About the Author

Annie Boynton is a multi-credentialed coder and the director of 5010/ICD-10 communication, adoption and training for UnitedHealth Group. She is a developing member of the AAPC’s ICD-10 training team. Annie frequently speaks and writes about coding matters, including ICD-10 and 5010 implementation.

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