In a final rule (PDF) issued Thursday afternoon, HHS formally set an Oct. 1, 2015, compliance date for conversion to ICD-10 diagnostic and procedure codes, incorporating the absolute minimum delay imposed by Congress when it ordered HHS to roll back the conversion date previously set for Oct. 1, 2014.
The congressional mandate in late March was inserted in a single sentence slipped into the annual “doc fix” legislation for the Medicare sustainable growth-rate formula.
The bill was signed into law by President Obama on April 1.
On April 30, in a proposed rule on the inpatient prospective payment system, the CMS made several references to an Oct. 1, 2015 start date for ICD-10 and the CMS confirmed in a terse statement the following day that an “interim final rule” would have Oct. 1, 2015, as the target date.
The issuance of the ICD-10 compliance deadline in a final rule is significant because it accelerates the rule-making process by a step and in so doing does not provide for a formal comment period for discussion of the date, according to health information technology consultant Stanley Nachimson, an ICD-10 expert.
“ICD-10 codes will provide better support for patient care, and improve disease management, quality measurement and analytics,” CMS Administrator Marilyn Tavenner said in a news release.
“For patients under the care of multiple providers, ICD-10 can help promote care coordination.”
For long-time ICD-10 boosters, the minimum delay was good news.
“We're happy it came out,” said Lynne Thomas Gordon, CEO of the American Health Information Management Association. “Everybody in healthcare loves to have a deadline. Now, we've got a date. Let's ramp up.”
Many hospitals were well down the road to getting ready for ICD-10 when Congress forced a postponement of the conversion, Gordon said. Since then, many organizations have kept up with their ICD-10 preparations, albeit at a slower pace due to the delay, she said.
At a recent AHIMA meeting for representatives from its state organizations, Gordon said, “We probably had over 200 people there. Everyone I talked to except one said they were just going on” implementing training, dual-coding in ICD-9 and ICD-10 and other preparatory activities, she said,
But for those who had pleaded with HHS for an ICD-10 delay, saying providers, vendors and even some Medicare claims processing contractors might not be ready by Oct. 1, 2014, a postponement of just one year still might not be enough time.
“This conversion has proven so far to be extremely difficult for practices and their trading partners to accomplish,” said Robert Tennant, senior policy adviser for the Medical Group Management Association. “Despite the additional time, facing multiple federal quality reporting requirements and an uncertain payment environment, practices may continue to experience challenges with software upgrades, workflow modification and staff training.
“Absent Medicare and other public and private health plans aggressively pursuing end-to-end testing and being fully transparent in terms of payment policies well in advance of the compliance date, we remain concerned that cash flow following Oct. 1, 2015, could be disrupted,” Tennant said. “We will continue efforts to educate our members on this complex change and prepare them for this transition.”
Follow Joseph Conn on Twitter: @MHJConn
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