Updated on: March 16, 2016

Further Delay in ICD-10 Implementation “Unacceptable,” says AHIMA Official

Original story posted on: June 20, 2012

Any possible delay of the implementation of the ICD-10-CM coding system is “unacceptable,” said Dan Rode, vice president, advocacy and policy, American Health Information Management Association (AHIMA), during his testimony at the June 20, 2012, meeting, of the National Committee on Vital and Health Statistics (NCVHS) Subcommittee on Standards.


What is acceptable, in Rode’s opinion, is for the NCVHS to encourage the Department of Health & Human Services (HHS) to issue a final rule as soon as possible and establish Oct. 1, 2014, as a firm compliance date for the new system—and for good reasons.

As Rode says, “Another delay will continue to raise the cost of implementation, hinder the benefits gained from the new system, impede progress toward government mandates and segments of the healthcare industry will continue to request additional delays.”

At the June 20 meeting, the NCVHS received an earful of ICD-10-related testimony from a cross-section of the healthcare industry, representing physicians, coders, vendors, payers, health information management (HIM) professionals, information technology (IT) professionals, and others. The committee invited these individuals to share experiences and challenges related to their transition to ICD-10 as well as to identify and discuss key industry milestones needed to ensure successful transition, taking the pending one-year compliance delay into consideration.


The panel consisted of the following:

  • Simon Cohn, MD, MPH, associate executive director, health information policy, The Permanente Federation, Kaiser Permanente and former chair of the NCVHS
  • Dan Rode, MBA, CHPS, FHFMA, vice president, advocacy and policy, American Health Information Management Association (AHIMA)
  • Stanley Nachimson, principal of Nachimson Associates, and HIMSS ICD-10 task force co-chair
  • Mona Reimers, FACMPE, CPC, director of revenue services, Orthopaedics Northeast PC, representing the Medical Group Management Association (MGMA)
  • Dennis Winkler, technical program director, Blue Cross Blue Shield of Michigan
  • Sidney Hebert, ICD-10 program manager for Humana Inc., representing America’s Health Insurance Plans (AHIP)
  • Holly Louie, CHBME, chair of the Healthcare Billing & Management Association (HBMA) ICD-10 committee

Addressing the Uncertainty

Most of those who presented testimony believe it is mandatory for HHS to announce a final ICD-10 compliance date as soon as possible. The dissenting opinion came from Mona Reimers, representing the physician-focused MGMA.

As for the concern of others, Simon Cohn, who provided the overview for the panel, stated, “The uncertainty about the compliance date is impacting organizational re-planning and resourcing efforts. Impacted organizations are concerned that the implementation date may be moved a second time, as occurred recently with 5010. Announcing a final decision on the compliance date in a timely manner is one of the most important things HHS can do to help assure timely implementation.”


To this comment, Sidney Hebert later added, “The continued uncertainty regarding the enforcement deadline for 5010 over the first 6 months of 2012 have demonstrated the high costs associated with delayed enforcement dates that are often extended at the last minute. … Further changes to the ICD-10 compliance date or similar ‘enforcement delays’ throughout 2013 and 2014 prior to the October 1, 2014 deadline would cause significant costs for health plans and ultimately for their customers…”

Ready or Not?

“We must learn from the mistakes that were made in transitioning from 4010 to 5010, and undertake the transition from ICD-9 CM to ICD-10 CM in a way that demonstrates we learned those lessons,” Holly Louie remarked. “We cannot stress enough that in relative terms, adoption and implementation of 5010 was simple compared to the much greater magnitude of ICD-10 CM.”

In fact, so important a point is this that she entitled her testimony as “ICD-10: Avoiding the 5010 Pitfalls” and proceeded to present very solid evidence about what went wrong and how HHS and the industry could prevent a repeat of the mistakes. In the view of HBMA, Louie said a central shortcoming in the 5010 transition was the lack of a standard definition of what it meant to be “5010 ready.”

She explains, “In early 2010, billing companies were being told by practice management vendors, clearinghouses and health plans that they were ‘5010 ready.’ Similarly, HBMA was being told by its members that they, too, were ‘ready.’ Technically, the entities that were saying they were ‘5010 ready’ in early 2010 were not misrepresenting their status as far as that term could be applied at that point in time; however, realistically, no one could have been 5010 ready in early 2010 because no one was in a position to test. What we subsequently learned was that every entity in the claims processing chain had a different definition of what they meant by the term…”




Therefore, HBMA believes that HHS should adopt and enforce a uniform definition of ICD-10-CM “ready.” As was the case for the 5010, some vendors and health plans have already announced that they are ICD-10-CM “ready,” but, Louie says, “Clearly, this cannot be true as there has been no external end-to-end testing or payment impact analysis for claims other than the CMS-3M project for DRG to ICD-10 comparison.”

In her opinion, ICD-10-CM ready should mean, at a minimum, “The complete end-to-end testing of 837 and 835 transactions in full production has successfully been accomplished. Any maps or crosswalks used by a health plan to adjudicate a 5010/ICD-10 CM compliant claim must be publicly available and the diagnosis code(s) used for claims adjudication are reported.

Any entity (billing company, software vendor, clearinghouse health plan, provider, etc.) that cannot document that they meet this definition of ready, should be prohibited from publicly asserting that they are ICD-10 CM ‘ready.’ Entities improperly asserting ICD-10 CM readiness would be subject to fines and penalties.”

Hebert agrees that that HHS and NCVHS need to work to develop a detailed ICD-10 testing and implementation plan that would allow for covered entities to begin testing around October 1, 2013, and continue until the revised implementation date. This program should also include milestones and metrics that would be monitored to better understand the state of the industry.

Other stakeholders have suggested dual implementation periods for health plans and providers or staggered implementation dates as well as a phase-in for the implementation of ICD-10 procedure codes and diagnostic codes.  On behalf of MGMA, Reimers recommended that clearinghouses and health plans should comply first and then providers would comply with the standard a minimum of 12 months later. Testing would occur during this period with financial help from the Centers for Medicare & Medicaid Services.

On behalf of the AHIP, Hebert disagrees: “Both of these approaches would be nearly impossible to implement from an operational perspective and would cause great challenges both in the development of health plan and provider contracts as well as the implementation of quality improvement strategy reporting, which depends on ICD-10 diagnostic and procedure codes,” he said. “It would also add significant costs and marketplace confusion to the implementation of ICD-10.”


Stanley Nachimson started out his presentation by commenting upon vendor readiness and, like Louie, identified the risk involved in that phrase, saying, There is no ‘true’ definition of vendor readiness in the healthcare community; therefore, it is difficult for organizations to determine if their vendors are ready to support the transition to ICD-10.”

To address this fact, he recommends that vendor self-reporting be accelerated and encouraged by HHS and also advised the agency to provide financial and staffing resources as a participant in the creation of an ICD-10 National Pilot Program with end-to-end standardized testing that mirrors the actual processing environment.

As he said, “Plans are uncertain of how to set up end-to-end testing, particularly if an organization has not implemented electronic remittance advice transaction.” Program participants for such a program would include associations, payers, providers, vendors, financial institutions, government, and clearinghouses

Strengthening the Payer-Provider Link

Since the implementation started, Dennis Winkler says the industry has learned the following: “Not all payers understand/appreciate the provider’s point of view, and not all providers understand/appreciate the payers’ point of view.” This is why it’s essential to bring all parties to the table to discuss and understand each others’ challenges with the transition.

In his role as health plan representative, Winkler cited “open payer and provider collaboration” as the common denominator associated with successful continuation.

“If we can achieve a level of consensus and open collaboration/working together, we’d be able to start moving in the same direction and ultimately at the same pace,” he said. A suggestion would be for HHS to endorse and support a payer and provider summit toward that end.

Rode agrees, saying, “…we are all in this together as we also work to implement and use health information technology. There are opportunities to make implementation easier as we consider requirements such as testing.”

Focus on Getting to the End

Most of those who gave testimony to NCVHS urge all healthcare information stakeholders to continue their work to ensure compliance with the ICD-10-CM and ICD-10-PCS requirements in spite of any delay. Several, including AHIMA, urged the NCVHS, healthcare colleagues and the federal government to provide a strategic plan.


As Rode said, “The bottom line is that ICD-10-CM and ICD-10-PCS are a lynchpin for the value of healthcare systems and the revolution now occurring in the United States for creating more efficient and effective tools for managing health information across all provider settings. Delay in ICD-10-CM and PCS will delay the benefits of this revolution in all but the most sophisticated health systems or plans.

Janis Oppelt

Janis keeps the wheel of words rolling for Panacea®'s publishing division. Her roles include researching, writing, and editing newsletters, special reports, and articles for RACMonitor.com and ICD10Monitor.com; coordinating the compliance question of the week; and contributing to the annual book-update process. She has 20 years of experience in topics related to Medicare regulations and compliance.