Published April 3, 2014

ICD-10 Delay: So Now What?

“The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD-10 code sets as the standard for code sets….”

This one little sentence – the sum and substance of Section 212 of HR 4302, Protecting Access to Medicare Act of 2014 – has thrown a hefty wrench into providers’ ICD-10 transition strategies.

Prior to this week, the Centers for Medicare & Medicaid Services (CMS) had been unequivocal in stating there would be no delay of the October 1, 2014, deadline for ICD-10 transition.  According to CMS, another one-year delay would likely cost the industry an additional $1 billion to $6.6 billion, on top of the costs incurred from the previous one-year delay (October 1, 2013, to October 1, 2014).

On Monday, however, HR 4302 passed the Senate, and the President is expected to sign it into law this week.  The bill avoids the nearly 24% cut in Medicare Physician Fee Schedule payments that was to take effect April 1.  But it also includes the ICD-10 delay, even though no Senator made mention of the delay during the four-hour floor debate on the legislation.

For now, CMS remains mum on the ICD-10 delay, but there are critical questions that need to be answered in short order:

  • Will October 1, 2015, become the new deadline?
  • Will CMS allow organizations that are ready to implement ICD-10 to do so voluntarily?
  • Will CMS scrap ICD-10 altogether and instead wait for ICD-11, which is due to be released in 2017?

The College of Healthcare Information Management Executives (CHIME) was quick to state its disapproval of the delay:  “We understand the considerable hours, resources, and money CHIME members and their organizations have spent preparing for the transition. This pause in momentum discredits the significant work our industry has spent training staff, conducting testing, and converting systems; not to mention the hold on improving care quality and accuracy, advancing clinical reporting and research, and patient safety outcomes.”

The American Health Information Management Association (AHIMA) remains committed to moving forward:   “Since the transition to ICD-10 remains inevitable and time-sensitive because of the potential risk to public health and the need to track, identify and analyze new clinical services and treatments available for patients, AHIMA will continue to help lend technical assistance and training to stakeholders as they are forced to navigate the challenge of continuing to prepare for ICD-10 while still using ICD-9.”

The American Medical Association (AMA) opposed HR 4302, despite its support for delaying the ICD-10 implementation date.  The AMA promises to continue its efforts to ease the pain of the transition: “The AMA remains committed to relieving physicians of the crushing administrative burdens and practice disruptions that are anticipated during the scheduled transition to ICD-10.”

We will provide regular updates as CMS provides clarification and once the full impact of the delay becomes clear.

In the face of uncertainty, however, one thing is clear:  providers should not mothball their clinical documentation improvement efforts.  Those efforts have been driven in part by the level of specificity required by ICD-10, but capturing complete and accurate clinical documentation of a patient’s condition has many more benefits.  In the face of aggressive payer audits, medical necessity for all services must be properly documented within the patient record.

Also, with Medicare and commercial payers moving to risk-sharing and risk-bearing contracts in the next few years, one critical success factor for providers will be the ability to accurately portray the level of risk within the provider’s patient population.  To paint this picture, providers must have available detailed documentation regarding patients’ histories and presenting conditions.

PYA has extensive experience performing ICD-10 readiness assessments, conducting training and education, and developing and implementing effective clinical documentation improvement programs.  With our skills, experience, and AHIMA ICD-10 certified trainers, PYA consultants can be a resource to navigate your organization through this uncertain time.

For more information, contact the experts listed below at PYA, (800) 270-9629.

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Published April 2, 2014

ICD-10 Delay: So Now What?

The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD-10 code sets as the standard for code sets….”

This one little sentence – the sum and substance of Section 212 of HR 4302, Protecting Access to Medicare Act of 2014 – has thrown a hefty wrench into providers’ ICD-10 transition strategies.

Prior to this week, the Centers for Medicare & Medicaid Services (CMS) had been unequivocal in stating there would be no delay of the October 1, 2014, deadline for ICD-10 transition.  According to CMS, another one-year delay would likely cost the industry an additional $1 billion to $6.6 billion, on top of the costs incurred from the previous one-year delay (October 1, 2013, to October 1, 2014).

On Monday, however, HR 4302 passed the Senate, and the President is expected to sign it into law this week.  The bill avoids the nearly 24% cut in Medicare Physician Fee Schedule payments that was to take effect April 1.  But it also includes the ICD-10 delay, even though no Senator made mention of the delay during the four-hour floor debate on the legislation.

For now, CMS remains mum on the ICD-10 delay, but there are critical questions that need to be answered in short order:

  • Will Oct. 1, 2015, become the new deadline?
  • Will CMS allow organizations that are ready to implement ICD-10 to do so voluntarily?
  • Will CMS scrap ICD-10 altogether and instead wait for ICD-11, which is due to be released in 2017?

The College of Healthcare Information Management Executives (CHIME) was quick to state its disapproval of the delay:  “We understand the considerable hours, resources, and money CHIME members and their organizations have spent preparing for the transition. This pause in momentum discredits the significant work our industry has spent training staff, conducting testing, and converting systems; not to mention the hold on improving care quality and accuracy, advancing clinical reporting and research, and patient safety outcomes.”

The American Health Information Management Association (AHIMA) remains committed to moving forward:   “Since the transition to ICD-10 remains inevitable and time-sensitive because of the potential risk to public health and the need to track, identify and analyze new clinical services and treatments available for patients, AHIMA will continue to help lend technical assistance and training to stakeholders as they are forced to navigate the challenge of continuing to prepare for ICD-10 while still using ICD-9.”

The American Medical Association (AMA) opposed HR 4302, despite its support for delaying the ICD-10 implementation date.  The AMA promises to continue its efforts to ease the pain of the transition: “The AMA remains committed to relieving physicians of the crushing administrative burdens and practice disruptions that are anticipated during the scheduled transition to ICD-10.”

We will provide regular updates as CMS provides clarification and once the full impact of the delay becomes clear.

In the face of uncertainty, however, one thing is clear:  providers should not mothball their clinical documentation improvement efforts.  Those efforts have been driven in part by the level of specificity required by ICD-10, but capturing complete and accurate clinical documentation of a patient’s condition has many more benefits.  In the face of aggressive payer audits, medical necessity for all services must be properly documented within the patient record.

Also, with Medicare and commercial payers moving to risk-sharing and risk-bearing contracts in the next few years, one critical success factor for providers will be the ability to accurately portray the level of risk within the provider’s patient population.  To paint this picture, providers must have available detailed documentation regarding patients’ histories and presenting conditions.

PYA has extensive experience performing ICD-10 readiness assessments, conducting training and education, and developing and implementing effective clinical documentation improvement programs.  With our skills, experience, and AHIMA ICD-10 certified trainers, PYA consultants can be a resource to navigate your organization through this uncertain time.

For more information, contact Denise Hall or Kristen Lilly at PYA, (800) 270-9629.

 

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