April 17, 2012

Possible ICD-10 Implementation Delay: Is This Good News?

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The Department of Health & Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) understand the difficulties that providers are dealing with to comply with the complexity of required changes to implement the ICD-10-CM diagnosis and PCS coding systems across the healthcare industry. They have reviewed the requirements for all covered entities to ensure a smooth transition in updating this new code set and the lack of success or failure if just one segment of the industry fails to comply. It would be a domino effect of negativity for the entire healthcare industry if failure occurs.

Consequently, HHS and CMS issued a proposal with three topics of focus. Two of the topics relate to establishing additional identifiers related to health plans and the third is for a possible one-year delay of ICD-10 implementation with a go-live date of October 1, 2014.

CMS believes the “change in the implementation date to October 1, 2014, would give providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition by all industry segments”[1]. You owe it to your practice to read the 168 page document (http://www.ofr.gov/OFRUpload/OFRData/2012-08718_PI.pdf), which contains a recap of ICD-10 information while providing CMS’s rationale for possibly entertaining the change in implementation date.

After reading, you may realize that you have supporting evidence that these changes are not beneficial to your business and may want to submit comments to CMS within the 30-day comment period that begins on the date the proposal formally appears in the Federal Register, which is expected to be today (April 17, 2012). Whether or not CMS makes changes, your comments will be “heard” and recorded in the Federal Register. Sometimes a well-described comment offers evidence and acts as a catalyst for change, possibly in the details of the wording, and affects many other providers similar to yours.

Comments may be submitted in one of four ways: electronically, by regular mail, by express or overnight mail, and by hand or courier. Exact details about submission can be found at the end of the summary section at the above website address.

a. For delivery in Washington, DC--

b. For delivery in Baltimore, MD--

About the Author

Anita Archer has extensive management experience in the healthcare industry, with an emphasis on revenue cycle management and systems implementation and support. She is a certified professional coder and an AHIMA-approved ICD-10-CM/PCS trainer, and has been responsible for revenue cycle improvements in physician practices, hospitals and ancillary services. She has extensive system implementation experience and is a superb project manager and team leader. Anita is currently the director of regulatory compliance at Hayes Management Consulting.

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[1] DEPARTMENT OF HEALTH AND HUMAN SERVICES Office of the Secretary   45 CFR Part 162 [CMS-0040-P] RIN 0938-AQ13 Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to the Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets

Read 108 times Updated on September 23, 2013
Anita Archer, CPC

Anita Archer has extensive management experience in the healthcare industry, with an emphasis on revenue cycle management and systems implementation and support. She is a certified professional coder and an AHIMA-approved ICD-10-CM/PCS trainer, and has been responsible for revenue cycle improvements in physician practices, hospitals and ancillary services. She has extensive system implementation experience and is a superb project manager and team leader. Anita is currently the director of regulatory compliance at Hayes Management Consulting.