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In 2009, the U.S. Department of Health and Human Services (HHS) published the first ICD-10 final rule requiring the adoption of the new code sets for services rendered on and after Oct. 1, 2013. This was after representatives of the industry requested that this date be moved back from the initial proposed date of Oct. 1, 2011, with those representatives claiming that the additional time was necessary to effectively and properly implement the changes. There were estimates of considerable costs and considerable benefits to the industry for the process, with many of the costs falling on providers and many of the benefits accruing to public health entities and health plans. Many hailed the regulation, but there was grumbling in several quarters.

Yet despite recommended timelines and guidance provided to the industry by WEDI, AHIMA, HIMSS, and others, industry participants fell behind on the intermediate benchmarks for the project. Providers, plans, and vendors all focused their attention on other priorities, the Centers for Medicare & Medicaid Services (CMS) provided an “enforcement moratorium” for the conversion to the new 5010 transaction versions (effectively instituting a delay), and in late 2011 and 2012 several organizations started pressuring CMS to grant the industry extra time for ICD-10 implementation. CMS relented, publishing a proposed rule and a final rule in 2012 granting an additional one year for implementation – the new deadline being Oct. 1, 2014. This was a bit of a compromise between those who wanted no delay and those who wanted an even longer delay (or an abandonment of the change altogether).

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