Although the compliance deadline has been pushed back by two years to 2013, the long-awaited and, by all accounts, expensive and difficult transition to the International Classification of Diseases, 10th Revision, code sets has officially begun.
HHS has released the final rule for implementing ICD-10 CM (Clinical Modification) and ICD10-PCS (Procedure Coding System), shifting the compliance deadline from Oct. 1, 2011, in the proposed rule, to Oct. 1, 2013. The proposed rule was issued last August and presented for public comments, which apparently affected the deadline change.
The ICD-10 conversion rule came in a 185-page amendment to the rules covering transactions and code sets under the 1996 Health Insurance Portability and Accountability Act. It noted that “most commenters disagreed” with the earlier compliance date, “stating that it did not provide adequate time for industry to train coders and complete systems changeovers and testing.”
In companion rulemaking, HHS also posted a final rule covering an upgrade from the X12 Version 4010 data-transmission standards in current use to Version 5010, which is a prerequisite to an ICD-10 conversion because those codes are larger and more complex than ICD-9 codes.
The proposed rule on 5010 also released last August called for an Oct. 1, 2010 deadline for conversion to the 5010 transactions standards. In the final rule, HHS settled on Jan. 1, 2012, for compliance with the 5010 standards.
“These regulations will move the nation toward a more efficient, quality-focused healthcare system by helping accelerate the widespread adoption of health information technology,” HHS Secretary Mike Leavitt said. “The greatly expanded ICD-10 code sets will fully support quality reporting, pay-for-performance, bio-surveillance and other critical activities. The updated X12 transaction standards, Version 5010, provide the framework needed to support the ICD-10 codes.”
The American Health Information Management Association has been stumping for the ICD-10 upgrade for 15 years and the National Committee on Vital and Health Statistics, the official IT advisory panel to HHS under HIPAA, first recommended the upgrade in the early 1990s, according to Sue Bowman, director of coding policy and compliance for the Chicago-based association of medical records professionals.
AHIMA caught flak from several directions for its stance in support of the original ICD-10 deadline, but Bowman said even with the delayed start, “We're just happy finally having a rule out and being able to move forward after 15 years working on this.
According to an estimate of costs and benefits included in the proposed rule, implementing the changes will cost a total of nearly $3 billion. Those costs will begin to occur in 2011 and run through 2017. But HHS estimates the total benefits of the conversion at $4.5 billion, accruing between 2015 and 2025.
“The costs are going to come before we can reap the rewards of the savings, but it is just something we have to do, not just for the benefit of a better coding system,” Bowman said. “We just can’t stay with ICD-9 much longer. It’s not going to last much longer. If we had done this earlier, it would have been cheaper. It’s just time to bite the bullet and reap the benefits of having better healthcare data.”
Bowman said the upgrade requirement “fits very nicely” with a proposal by President-elect Barack Obama to dramatically boost federal support for spending on healthcare IT, with numbers being bandied about into the range of tens of billions of dollars. Providers need to make sure the 5010 and ICD-10 upgrades are discussed with their IT vendors.
“We’ve said all along as you upgrade systems or implement new systems you should talk to your vendor to make sure they incorporate ICD-10 readiness into that system,” Bowman said. The release of the final rules just gave the “official greenlight” to moving those conversations from the hypothetical into the real. “Of course, with Obama pressing IT readiness, people should insist that ICD-10 should be a part of that process.”
George Arges, senior director of health data management group at the American Hospital Association, said the deadline was a year later than the association had requested, but with the slowing economy, “I think we’re happy with the timeline. I think the time frame that was put forward was aggressive, but realistic.” Now that the ICD-10 deadline is fixed, “people can put money into IT and components.”