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ICD-10 Implementation to Be Delayed

April 27, 2012:

Karen Kachur, RN, CPC, Clinical/Technical Editor

All of the rumors and speculation surrounding a delay in the date for compliance with ICD-10-CM and -PCS have finally been put to rest. In a proposed rule published in the April 17, 2012, Federal Register, the Department of Health and Human Services (HHS) announced its intention to delay compliance one year, from October 1, 2013, to October 1, 2014.

The department considered a number of alternatives before proposing the one-year delay. While cost estimates due to this setback are expected to be in the range of $1 billion to $6.4 billion, a Regulatory Impact Analysis (RIA) anticipates an offset of $3.6 to $8 billion by avoiding costs associated with the October 1, 2013, compliance date arising from so many unprepared providers.

Recent surveys of and concerns voiced by providers have suggested that the industry is not on track for the October 1, 2013, compliance date. One of the primary concerns pertains to the industry’s ability to meet the compliance deadline for the Associated Standard Committee's (ASC) X12 5010 standards (version 5010) for electronic health care transactions, which is necessary prior to ICD-10 implementation. Although the initial effective date for version 5010 was slated for January 1, 2012, the Centers for Medicare and Medicaid Services announced in November 2011 that enforcement actions would not be initiated for noncompliance until March 31, 2012, a date that was then again moved back to June 30, 2012. To enable a smooth conversion, all entities must transition to ICD-10 at the same time as one industry segment’s inability to comply with ICD-10 would adversely affect all other industry segments, with subsequent problems arising from delayed payment and rejected claims. The agency believes the one-year delay would provide needed time for adequate preparation and testing to ensure a seamless transition.

Causing further consternation are other significant statutory initiatives with comparable dates of compliance that affect provider reporting and compliance, such as the EHR Incentive Program, the eRX Incentive Program, and the Physician Quality Reporting System (PQRS). Providers worry they will not have sufficient resources to implement so many initiatives simultaneously.


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