DHHS Receiving Commentary with Respect to ICD-10 Implementation

The shift from ICD-9 to ICD-10 coding will necessitate a considerable amount of effort and most certainly will impact the way coding is currently performed.  Since DHHS’ announcement to delay the implementation of ICD-10 compliance in February 2012, numerous organizations have stepped forward with concerns and recommendations in relation to this issue. 

Susan Turney, President and CEO of MGMA requested in writing on March 1, 2012 that in addition to delaying the ICD-10 implementation, the DHHS take the following seven steps to improve the thoroughness of the process.

  • Complete a comprehensive cost benefit analysis to determine how each aspect of the healthcare industry will be impacted by the ICD-10 change
  • Pilot test ICD-10 to identify issues and potential road blocks prior to the implementation
  • Analyze the administrative and financial impact of overlapping initiatives
  • Evaluate additional code set approaches including current ICD-9 code processes and assessing changes necessary to improve the ICD-9 code set
  • Stagger implementation dates for different sectors
  • Develop appropriate crosswalks to minimize the loss of historical data
  • Require certification of all affected health plans

Additionally, in a May 2012 letter to DHHS, Executive Vice President and CEO James Madara, M.D. of the AMA requested ICD-10 implementation be delayed to October 2015, stating “a years delay does not provide CMS with adequate time to fully examine the appropriate scope of the ICD-10 and true costs to physician practices.”  Similar to the views of MGMA, the AMA feels a cost benefit analysis and phasing in aspects of the implementation will benefit not only the industry but also CMS’ understanding of the massive undertaking the healthcare industry will experience.  Current ongoing implementation of IT programs for healthcare industry such as the value-based modifier, e-prescribing, PQRS, and EHR, combined with the ICD-10 implementation will increase the burden on the industry significantly.

Several other organizations have submitted commentary to DHHS surrounding this topic and the impact it would have upon their industry. DHHS is now reviewing all comments submitted as the last day to submit comments was May 17th.  

As indicated in our February blog post, the switch to ICD-10 codes, when enacted, will not only have an impact on the medical provider community, but also on the insurance industry.  Currently, MMSEA Section 111 Reporting involves the usage of ICD-9 codes to communicate diagnoses of Medicare beneficiaries to CMS, RREs and reporting agents will be required to implement the necessary changes to their data submission processes when ICD-10 codes are implemented.  We believe that the insurance industry shares many of the same concerns as the healthcare industry and would welcome a cost benefit analysis being performed prior to a final implementation date being established. 


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