Any possible delay of the implementation of the ICD-10-CM coding system is “unacceptable,” said Dan Rode, vice president, advocacy and policy, American Health Information Management Association (AHIMA), during his testimony at the June 20, 2012, meeting, of the National Committee on Vital and Health Statistics (NCVHS) Subcommittee on Standards.

What is acceptable, in Rode’s opinion, is for the NCVHS to encourage the Department of Health & Human Services (HHS) to issue a final rule as soon as possible and establish Oct. 1, 2014, as a firm compliance date for the new system—and for good reasons.

As Rode says, “Another delay will continue to raise the cost of implementation, hinder the benefits gained from the new system, impede progress toward government mandates and segments of the healthcare industry will continue to request additional delays.”

At the June 20 meeting, the NCVHS received an earful of ICD-10-related testimony from a cross-section of the healthcare industry, representing physicians, coders, vendors, payers, health information management (HIM) professionals, information technology (IT) professionals, and others. The committee invited these individuals to share experiences and challenges related to their transition to ICD-10 as well as to identify and discuss key industry milestones needed to ensure successful transition, taking the pending one-year compliance delay into consideration.

The panel consisted of the following:

• Simon Cohn, MD, MPH, associate executive director, health information policy, The Permanente Federation, Kaiser Permanente and former chair of the NCVHS
• Dan Rode, MBA, CHPS, FHFMA, vice president, advocacy and policy, American Health Information Management Association (AHIMA)
• Stanley Nachimson, principal of Nachimson Associates, and HIMSS ICD-10 task force co-chair
• Mona Reimers, FACMPE, CPC, director of revenue services, Orthopaedics Northeast PC, representing the Medical Group Management Association (MGMA)
• Dennis Winkler, technical program director, Blue Cross Blue Shield of Michigan
• Sidney Hebert, ICD-10 program manager for Humana Inc., representing America’s Health Insurance Plans (AHIP)
• Holly Louie, CHBME, chair of the Healthcare Billing & Management Association (HBMA) ICD-10 committee

Addressing the Uncertainty

Most of those who presented testimony believe it is mandatory for HHS to announce a final ICD-10 compliance date as soon as possible. The dissenting opinion came from Mona Reimers, representing the physician-focused MGMA.

As for the concern of others, Simon Cohn, who provided the overview for the panel, stated, “The uncertainty about the compliance date is impacting organizational re-planning and resourcing efforts. Impacted organizations are concerned that the implementation date may be moved a second time, as occurred recently with 5010. Announcing a final decision on the compliance date in a timely manner is one of the most important things HHS can do to help assure timely implementation.”

To this comment, Sidney Hebert later added, “The continued uncertainty regarding the enforcement deadline for 5010 over the first 6 months of 2012 have demonstrated the high costs associated with delayed enforcement dates that are often extended at the last minute. … Further changes to the ICD-10 compliance date or similar ‘enforcement delays’ throughout 2013 and 2014 prior to the October 1, 2014 deadline would cause significant costs for health plans and ultimately for their customers…”

Ready or Not?

“We must learn from the mistakes that were made in transitioning from 4010 to 5010, and undertake the transition from ICD-9 CM to ICD-10 CM in a way that demonstrates we learned those lessons,” Holly Louie remarked. “We cannot stress enough that in relative terms, adoption and implementation of 5010 was simple compared to the much greater magnitude of ICD-10 CM.”

In fact, so important a point is this that she entitled her testimony as “ICD-10: Avoiding the 5010 Pitfalls” and proceeded to present very solid evidence about what went wrong and how HHS and the industry could prevent a repeat of the mistakes. In the view of HBMA, Louie said a central shortcoming in the 5010 transition was the lack of a standard definition of what it meant to be “5010 ready.”

She explains, “In early 2010, billing companies were being told by practice management vendors, clearinghouses and health plans that they were ‘5010 ready.’ Similarly, HBMA was being told by its members that they, too, were ‘ready.’ Technically, the entities that were saying they were ‘5010 ready’ in early 2010 were not misrepresenting their status as far as that term could be applied at that point in time; however, realistically, no one could have been 5010 ready in early 2010 because no one was in a position to test. What we subsequently learned was that every entity in the claims processing chain had a different definition of what they meant by the term…”