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.”