Since the last newsletter, the ICD-10 deadline was delayed by Congress to a “no sooner than” Oct. 1, 2015 compliance date. This news was incredibly disappointing to many in this industry, especially those who had already invested a significant amount of resources to comply with the ICD-10 mandate.
As this was the fourth delay of the ICD-10 compliance date, some covered entities are a bit leery about whether to proceed and at what pace. After all, many of the project tasks such as coder training and external testing are best completed near the compliance deadline. What makes matters worse is that the AMA is still fighting to kill ICD-10. The AMA contends that this is an unfunded mandate and should be funded by the Federal government, similar to the “Meaningful Use” mandate.
This last-minute extension of the deadline by Congress even surprised CMS, which was completely blindsided after having repeatedly assured the industry that the 2014 deadline would not be delayed. In a June 4, 2014 letter to former Health and Human Services Secretary Kathleen Sebelius, Workshop for Electronic Data Interchange (WEDI) Chairman Jim Daley warned that, “since the Sustainable Growth Rate (SGR) is likely to require legislative action next year, there is concern that the ICD-10 compliance date will be extended yet again as part of that action…all of this has eroded industry confidence that any new date will be adhered to.”
While there is still a slim chance of yet another ICD-10 delay, I don’t believe it will be delayed again. These are the four factors that led me to this conclusion:
- ICD-11 is on the horizon. While there has been buzz about the possibility of foregoing ICD-10 completely in favor of the upcoming ICD-11 code set, that just isn’t practical. The beta version of ICD-11 is projected to be available by 2015, but the jump from ICD-9 to ICD-11 is simply too big to manage. Sue Bowman, Director of coding policy and compliance for AHIMA notes, “ICD-10 is the pathway to ICD-11. You have to treat it like you’re building a structure starting with a first floor. You can’t build a fourth one without constructing a second and third.”
- Successful testing. In March 2014, CMS tested with approximately 2,600 providers, suppliers, billing companies and clearinghouses, which made up a sample of 5% of all submitters. During this testing week, over 127,000 ICD-10 coded claims were submitted to the Medicare Fee-for-service (FFS) claims systems. On average, CMS accepted 89% of the test claims, with regional acceptance rates as high as 99%. No issues were found with the Medicare FFS claims systems during the testing week.
- Overall readiness. A recent AAPC study indicated that nearly 75% of respondents were well on their way to compliance. 25% had completed all ICD-10 training, 13% were ready to go, and 23% were actively testing with vendors when the bill to delay ICD-10 was signed. Less than a third of respondents were still in the beginning phases of preparation. From this data, it’s clear that pushing back ICD-10 once again would merely serve to punish those who have adhered to the implementation timeline – while some of their hard work will carry them through to the next deadline, they would surely need to retrain their staff and retest with partners.
- The cost is too high. The cost of another deadline delay in terms of wasted money, staff training, retesting, and missed opportunities for other projects that were sidelined in favor of ICD-10 implementation would be too great. The outcry that accompanied this latest deadline delay would pale in comparison to the uproar any further delay would cause.
Overall, the industry is still encouraging covered entities to continue testing. So don’t lose momentum! HCIM is offering help benchmarking where you’re at and readjusting your priorities. If you need help, please contact Laurie Kirkland at 949-290-6445 or firstname.lastname@example.org.
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