(This story was updated with additional comment at 12:05 p.m. ET.)
The countdown has restarted toward the compliance deadline with the federally mandated conversion to the ICD-10
diagnostic and procedural codes. The new ICD-10 start date is Oct. 1, 2015, according to a terse statement from the CMS.
But many of the problems and anxieties that led to last month's congressional pushback of the ICD-10 start date are still unresolved, several experts said.
HHS “expects to release an interim final rule in the near future that will include a new compliance date that would require the use of ICD-10 beginning Oct. 1, 2015,” the CMS statement said. “The rule will also require HIPAA-covered entities to continue to use ICD-9-CM through Sept. 30, 2015.”
The previous compliance deadline had been Oct. 1, 2014, but that was shot down by Congress in a law signed by President Barack Obama
on April 1 that ordered HHS to not set a ICD-10 compliance date any sooner than Oct. 1, 2015.
Physician groups led the charge in opposition to the 2014 deadline, citing a host of potential problems. Those included the inability of many vendors of electronic health-record
and practice-management systems to have their ICD-10 updated systems delivered in enough time for physicians and their staffs to have them installed; train themselves on how to use them; and have the claims generated by them adequately tested against the systems and rules of their health plans and claims clearinghouses.
Top of mind for doctors was the potentially crippling effects to their practices if their claims flows sputtered at the switchover from ICD-9 to ICD-10. Those concerns continue, even with the new date nearly 18 months away.
“We had been pushing for two things at the same time” before Congress intervened, said Dr. Reid Blackwelder, president of the American Academy of Family Physicians
. “We had been pushing for a delay in implementation until there was true end-to-end testing to make sure small practices would not be affected, and we were saying to our members if it was going to be Oct. 1, 2014, that small practices should be ready.”
End-to-end testing would ensure that a claim can be generated and sent by a physician practice or hospital, received by a clearinghouse and/or health plan, processed and adjudicated by the plan, and then accurately returned to the sending provider as a remittance advice and a funds transfer.
Blackwelder said his organization was “very pleased” with last month's delay. “We didn't believe things were ready to roll out. While larger practices could handle a glitch, smaller practices don't have the kinds of reserves to handle a payment challenge.” It remains to be seen, Blackwelder said, whether even the 18-month extension is sufficient to do the ICD-10 conversion right. “Enough time should be defined not by time but by successful demonstration of end-to-end testing,” he said.
The timeline to ICD-10 launch needs to be clearly delineated and communicated, said Dr. William Bria, president of the Association of Medical Directors of Information Systems, a professional association for physicians working in applied medical informatics. AMDIS members, he said, won't be shocked by the CMS' decision to reset the ICD-10 date with as little delay as possible.
But Bria warned of “a rapid crescendo of frustration and even anger beginning to appear (among) U.S. healthcare providers, especially physicians, that seems to be worsening with each pronouncement. It's past time that a clear and specific communication plan be laid out for all affected in American healthcare.”
Stanley Nachimson, principal with healthcare IT consultancy Nachimson Advisors and an ICD-10 expert, said the Workgroup for Electronic Data Interchange
, convened a meeting of representatives Tuesday from health plans, providers, health IT developers and the government to talk about a way forward on ICD-10. Simply plunking down a new deadline won't overcome resistance, Nachimson said. “We tried to engage with these folks who are against ICD-10 and change their minds or see what we could do to accommodate them,” he said. “I think there was a recognition that we have to change the way we do the ICD-10 implementation.”
Nachimson said he expects to see an interim final rule delivered by the CMS “sometime this month, and then it's going to open up the debate again.”
The American Medical Association
and the Medical Group Management Association
were among several physician groups that lobbied hard for a delay, and both still remain leery about the ICD-10 conversion.
“The AMA has long considered ICD-10 to be an unfunded mandate that comes at a time when physicians are being asked to make a number of other significant changes to their practices,” said AMA President Dr. Ardis Dee Hoven
, in a statement. “While the AMA did not support the legislation that extended the ICD-10 deadline because it failed to reform Medicare's flawed payment formula, we believe a delay would have been inevitable for a coding system that has not completed end-to-end testing. The postponement will give physicians extra time to work with vendors on necessary system updates, train their staff, and test the ICD-10 changes with payers, clearinghouses and others.”
Hoven said the industry should use the extra time “to conduct more robust and widespread testing on all aspects of ICD-10, including its application in reimbursement and quality reporting systems. We continue to harbor deep concerns about the burden this transition places on physicians, the complexity of ICD-10, the high risk of disruptions to Medicare claims and the industry's capability of converting to ICD-10 on a single date.”
Robert Tennant, the MGMA's senior policy adviser in Washington, attended the WEDI meeting with Nachimson and said if the group can come up with a list of “a half a dozen or a dozen things that the industry and government can reach agreement on, there is possibility there could be a seamless transition” to ICD-10 given the new deadline.
But, Tennant said health plans, vendors and the CMS had not done the necessary testing before the Oct. 1, 2014 deadline to ensure the ICD-10 launch would be successful. They must do those things now in the new, 18-month runup period, he said. “Without sufficient testing, providers will likely encounter significant cash-flow disruption,” he said.
The Chicago-based American Health Information Management Association
, a strong advocate for ICD-10 adoption and an opponent of delay, said in a written statement that it “applauds” the CMS' new start date. “We know that the industry has already invested considerable time and money in implementation,” the group said. “We particularly want to reach out to the physician community and are prepared to support programs such as the field support training for small physician practices proposed by CMS.”Follow Joseph Conn on Twitter: @MHJConn