The Federation of American Hospitals (FAH) has submitted to the Centers for Medicare & Medicaid Services its comments regarding the proposed delay for the implementation of ICD-10.

Signed by FAH President and CEO Charles N. Kahn III, the comments letter said the organization finds the current proposed one-year delay for implementation of ICD-10 appropriate and "very beneficial to the ultimate implementation of ICD-10."

The federation also said that all segments of the healthcare industry should transition to ICD-10 at the same time. "Hospitals already are overwhelmed with multiple priorities and activities with large resource and financial impacts. A delay increases a provider’s ability to better allocate the resources and dollars to accommodate these priorities. It also permits vendors and developers to fine-tune the systems and to create more robust necessary cross-walks," according to the letter.

Echoing other commenters, the FAH said its members who favor a one-year delay believe that a longer delay would require them to redo work already accomplished because systems inventory would be outdated and a reassessment would be time-consuming and costly.

Other FAH members favor a two-year delay, Kahn said, primarily to avoid the simultaneous implementation of ICD-10 and meaningful use Stage 2 that would occur with a one-year implementation. Regardless of which delay CMS chooses, FAH "strongly recommends that CMS establish benchmarks along the way that must be met to guarantee that an implementation delay will achieve its goal of more seamless integration of ICD-10 and a smooth transition that does not disrupt quality patient care."

Those benchmarks include the following:

• Specifying a trading partner testing schedule similar to what was done for 5010.
• Update all edits, manuals, National and Local Coverage Determinations (NDCs/LCDs), and quality measures to reflect ICD-10.

• Ensure that post-acute reporting tools and reimbursement methods are updated and that providers have an ability to assess the changes from both a clinical and payment perspective.
• Ensure the Impairment Group Codes (IGC) for Inpatient Rehabilitation Facilities are assessed and tested in ICD-10 so that medical cases captured by current ICD-9 codes under the so-called IRF “60 Percent Rule” will continue to satisfy that rule when coded in ICD-10.
• Monitor and report to the industry quarterly the State Medicaid program ICD-10 readiness status.
• Survey states to determine which DRG Grouper version they currently are using and make that information known to the field.
• Make available the provider impact files in order for providers to perform financial analysis and understand the impact of changes.  

FAH made several other recommendations regarding ICD-10 implementation, including hold off on enforcement and auditing activity until one year after implementation, create contingency plans for interim payments to hospitals once ICD-10 is implemented to allow for claims processing disruptions and have it align more closely with meaningful use requirements whereever possible, including implementation of SNOMED.

The comments are available in their entirety on the federation's website.