ED Coding and Reimbursement Alert

The ICD-10 Final Rule released announces implementation delay until October 2014; but don't wait too long to get up to speed on the new system.

The ICD-10 final rule was released in late August, which includes a decision on the proposed delay for mandatory compliance. This final rule changes the compliance date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding, including the Official ICD-10-CM Guidelines for Coding and Reporting, and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD--10--PCS) for inpatient hospital procedure coding, including the Official ICD--10--PCS for Coding and Reporting, from October 1, 2013 to October1, 2014.

CMS Offered An Explanation for Its Decision To Delay

CMS explained its decision was based on some providers' concerns about being able to meet the ICD-10 compliance date because of problems they had meeting the compliance deadline for the adopted Associated Standard Committee's (ASC) X12 Version 5010 standards (Version 5010) for electronic health care transactions.

According to a recent survey conducted by CMS, up to one quarter of the responding health care providers stated that they will not be ready for an October 1, 2013 compliance date, says Michael A. Granovsky, MD, FACEP, CPC, President of LogixHealth, an ED coding and billing company in Bedford, MA.

And The Survey Says...

In February 2012, the Workgroup for Electronic Data Interchange (WEDI) conducted a survey on ICD-10 readiness, receiving responses from more than 2,600 providers, health plans, and vendors showing that the industry is uncertain about its ability to meet ICD-10 compliance milestones. Data from the WEDI survey indicated that nearly 50 percent of the provider respondents did not know when they would complete their impact assessment. In addition, the survey found that approximately 33 percent of providers did not expect to begin external testing in 2013, while approximately 50 percent of providers did not know when testing would occur. Other segments of the industry, such as health plans and software vendors, also reported that they would benefit from additional time for implementation. While the CMS ICD-10 Implementation Guide recommends that payers begin external testing in the fall of 2012, the WEDI readiness survey found that most health plans do not expect to begin external testing until 2013. In addition, about 50 percent of vendors are not yet halfway through development of ICD-10 products. Vendor delays in product development can result in provider and payer delays in implementing ICD-10, Granovsky adds.

The Size Of Your Organization May Impact How You Feel About This Delay

Many large ED groups are far along in their ICD-10 implementation planning, and therefore have devoted funds, resources, and staff to the effort. According to CMS estimates, a 1-year delay of the ICD-10 compliance date would add 10 to 30 percent to the total cost that these entities have already spent or budgeted for the transition -- an additional cost to commercial entities of approximately $1 billion to $6.4 billion. For those entities that have already incurred considerable expense in order to meet the October 1, 2013 deadline, they opposed the delay because of likely additional cost associated with duplicating the investment of time and resources that has been spent on education, outreach, and policy discussions in order to meet the October 1, 2013 compliance date. They argue that coders, students, teaching institutions will need to be retrained because of the delayed compliance date, says Granovsky.

Just Because The Delay Has Been Finalized Does Not Mean You Can Forget About ICD-10!

Don't just forget about ICD-10 preparation. ED groups should look at this as an extension rather than a reprieve. The transition for ICD-9 to ICD-10 will take many months of preparation, training and external testing, so make sure you have a schedule and stick with it so you will be ready when the time comes. If you were well on your way in preparing for the transition next fall, you have some breathing room, but may need to consider some refresher her education because of the significant lag time between initial training and actual implementation. If you have not started getting ready, you should consider the extension a lucky break, because it will take time to be ready by 2014, warns Granovsky.