Daily Briefing Blog

ICD-10 was supposed to take effect today. It didn't. Here's why.

What you need to know about ICD-10 delays and deadlines


Clare Rizer, Daily Briefing

Payers and providers are one year away from the switchover from the ICD-9 to the ICD-10 code sets, which require them to change out about 18,000 codes for about 155,000 codes.

But the deadline wasn't always Oct. 1, 2015. In fact for some time, it was supposed to be today.  

Background on ICD-10

The transition to ICD-10 is required of all health care providers and insurers covered by HIPAA that submit claims to Medicare of Medicaid. The code set was first published by the World Health Organization in 1992 as a way to add mortality rate tracking. Since then, additional coding has been added to track diagnoses and treatments more broadly.

However, the road to ICD-10 implementation has not been smooth and has left many in the health care sector confused. "ICD-10 is a massive change that has huge implications for hospitals and all health care providers, but we are now in this realm of 'moral hazard' where it's gotten pushed back twice and preparations are very costly," says Ed Hock, managing director of Advisory Board Performance Technologies Marketing.

To help you understand these changes, we have compiled an overview of the changes to the ICD-10 timeline.

How the ICD-10 timeline has changed

August 21, 2008HHS issued a proposed rule that would have required health care providers to adopt ICD-10 code sets by October 2011. However, after receiving more than 3,000 comments on its proposal, HHS agreed to give health care providers until Oct. 1, 2013, to adopt ICD-10 code sets.

January 16, 2009: HHS released the final rule mandating that all HIPAA-covered entities implement ICD-10 for medical coding by Oct. 1, 2013.

August 24, 2012: HHS released a final rule that would delay the deadline for complying with ICD-10 standards by one year, moving it to Oct. 1, 2014. HHS said it decided to push back the compliance date partly because of health care providers' concerns that they would not be able to meet the initial deadline.

February 27, 2014: CMS Administrator Marilyn Tavenner announced at the 2014 Healthcare Information and Management Systems Society (HIMSS) convention in Orlando, Florida, that "There are no more delays and the system will go live on Oct. 1."

March 2014: CMS held an initial week of testing ICD-10 codes in which 89% of tested Medicare claims—or about 127,000—were "accepted" by 2,600 processing testers, which included claims clearinghouses, billing companies, providers, and suppliers.

April 1, 2014: President Obama signed into law legislation that pushed back the ICD-10 compliance date until at least October 2015. The delay was part of larger "doc fix" legislation to delay massive Medicare payment cuts for doctors. 

 

April 30, 2014: CMS issued a proposed rule setting the new ICD-10 compliance deadline as Oct. 1, 2015. The proposed rule states, "After that date, we will collect non-electronic health record-based quality measure data coded only in ICD-10-CM/PCS."

May 2, 2014: CMS pushed back end-to-end testing of ICD-10 codes until 2015. The agency had planned on conducting ICD-10 testing between July 21, 2014 and July 25, 2014 in order for a sample of providers to become familiar with using the codes.

Fitch: Delaying ICD-10 is a good thing for hospitals

July 31, 2014: CMS announced  a final rule establishing Oct. 1, 2015, as the new ICD-10 compliance deadline for payers and providers still making the transition.

2017: HHS is expected to release the final version of ICD-11 codes, two years later than scheduled.

Commenting on the delay and how it has impacted providers, Hock says, "Everyone is worried and it feels like this dynamic applies across the board of various providers."

He notes, "No matter how large an organization's size, they need to, at the very least, know exactly what they must do in order to meet compliance and they need to make sure they know exactly how long they have to make those preparations," adding, " because, come October 1, 2015, if providers have not made adequate preparations (under the assumption that the deadline would be moved again) they will—on top of facing penalties—be unable code or bill for the services they provide and the entire care process could fall apart."

Get a deeper look

Ed Hock sat down with me to discuss the changes to the ICD-10 timeline, the major concerns for hospitals amid the uncertainty, and how providers should use the next 365 days to get ready.

READ THE FULL Q&A NOW

Your ICD-10 crystal ball

See how ICD-10 Compass gives you the visibility needed to protect your revenue now and after the transition.

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Mitigating risks associated with ICD-10
Our business intelligence technology helps hospitals and health systems safeguard revenue by identifying pre- and post-transition ICD-10 risks, making root-cause analyses and risk mitigation efforts straightforward and transparent.

In addition, our dedicated advisors work closely with members to analyze problem areas, prioritize improvement opportunities, and share peer organizations’ best practices.

How we can help you to build your ICD-10 transition plan
We provide the people, processes, and expertise to develop a prioritized project plan and budget based on your hospital's priorities, needs, risks, and opportunities.

Our customized planning consulting services construct a multi-year detailed ICD-10 transition plan, a full budget allocation, and an optimal organizational structure, incorporating training and documentation needs and efficient resource allocation.

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