EDITOR’S NOTE: Healthcare consultant Stanley Nachimson, founder and principal of Nachimson Advisors, responds to an article recently published in the Journal of AHIMA, “Cost of Converting Small Physician Offices to ICD-10 Much Lower than Previously Reported.”

While I welcome attempts to refine and improve the estimates produced by the recently released 2014 Nachimson Advisors study, the American Health Information Management Association (AHIMA) journal article unfortunately contains several misstatements and invalid assumptions that render its conclusions misleading at best. I will point out several of these to show that the title and conclusion should be disregarded.

First, I note that my study includes costs for all of the tasks that should be undertaken in any ICD-10 implementation process. These tasks have been described in many guides about ICD-10 implementation; in fact the Centers for Medicare & Medicaid Services (CMS) website “Road to I-10,” which provides guidance targeted to small providers, lists these steps in its action plans. These tasks include planning and assessments, training, updating processes, engaging vendors and plans, and internal and external testing.

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