On the heels of comment submission regarding meaningful use Stage 2, healthcare associations are now submitting their conflicting comments on the notice of proposed rulemaking to postpone the compliance date for ICD-10 by one year to Oct. 1, 2014.
Arguably the largest proponent for the move to ICD-10, the American Health Information Management Association (AHIMA) focused its comments on the notice on the section addressing “Change to the Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets.”
AHIMA continues to recommend there be no delay in the ICD-10 compliance deadline but since a delay is likely, AHIMA stated that the association will continue to work with HHS and the healthcare industry to ensure the delay is as short as possible, preferably not more than one year.
“ICD-9 is antiquated and no longer adequately meets the challenge of a 21st century healthcare system,” said AHIMA CEO Lynne Thomas Gordon, MBA. “ICD-10 should be implemented in a timely manner, and AHIMA is ready to continue assisting the healthcare community to prepare for the transition. We also encourage advance testing of the ICD-10 codes to be sure there are no further delays in the implementation deadline.”
Dan Rode, MBA, AHIMA vice president for advocacy and policy, wrote, "ICD-10 is the foundation for other critical national healthcare initiatives such as meaningful use, value-based purchasing, payment reform, quality reporting and accountable care organizations. Without ICD-10, the value of these other efforts is greatly diminished.”
A delay of more than one year would cause additional confusion for colleges and universities as to what they should be teaching. Students already have been trained in ICD-10 and are forced to use ICD-9-CM when they enter the workforce.
AHIMA also advocated in the letter that transitioning directly to ICD-11 is not a viable option as implementation would not occur until after 2020, even in a best case scenario. In addition, the structure for ICD-10 is designed to make current and future healthcare technology systems ready for an easy transition to ICD-11.
In its comments, the College of Healthcare Information Management Executives (CHIME) urged the Department of Health and Human Services (HHS) to remain committed to ICD-10, while calling the one-year delay an appropriate “middle ground” for all stakeholders.
“A longer delay would seriously disrupt ongoing efforts to convert to ICD-10,” the letter said. “And, as HHS itself recognizes, a longer delay would significantly increase the costs of converting to ICD-10. Thus, we compliment HHS for attempting to balance the interests of all stakeholders by identifying a middle ground between those who urge a longer delay, which we believe would create more problems than it would solve, and those who would prefer no change in the compliance date.”
CHIME also complimented the unified approach proposed by HHS to ensure that all providers have the same compliance date. For the conversion to ICD-10 to proceed smoothly, CHIME recommended that all segments of the provider community be in lockstep regarding conversion timeframes. However, if HHS decides to entertain different ICD-10 compliance deadlines for different covered entities, CHIME said it would be most useful to set an earlier compliance date for payors.
“[A] consistent compliance date across the provider community and an earlier date for payers would make the delay much more meaningful,” the comments said.
Finally, CHIME recommended that HHS move steadily towards its proposed compliance deadline for ICD-10 and dismiss calls to “leapfrog” from ICD-9 to ICD-11. “Everyone in the healthcare IT world is working against numerous deadlines,” said George Hickman, executive vice president and chief information officer at N.Y.-based Albany Medical Center. “But it’s vitally important for those of us planning, budgeting and implementing these projects to know when those deadlines are coming. ICD-10 is a major undertaking, and we encourage HHS to be vigilant in monitoring industry readiness, while making clear its intentions regarding the final compliance date.”