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ICD…or not to be?

by Lauren H. Fifield, Senior Policy Advisor

Delays and more delays

Originally, the 10th revision of the International Statistical Classification of Disease and Related Health Problems--aka ICD-10--was slated for adoption here in the United States on October 1, 2011 by all “covered entities” under HIPAA.

As early as January 2009, the deadline was pushed out to October 1, 2013 and with it, migration to ANSI 5010 moved to January 1, 2012 in order to support ICD-10 codification. If, like me, you have become so immersed in the politics of such timing, just remember that the ANSI 5010 standard and ICD-10 code set updates are intended to be helpful, streamlining and improving transactions and improving diagnosis reporting and analysis.

Anyway, the “best-laid schemes of mice and men oft go awry”… unless you’re living in France, or one of the Nordic countries…circa 1997.

The industry transition to ANSI 5010 has been less than smooth and the Centers for Medicare and Medicaid Services (CMS) recently extended the enforcement start date to July 1, 2012. In response to feedback from organizations like the American Medical Association (AMA) regarding the administrative burden and cost of the ICD-10 transition, CMS announced in February that the agency would also consider postponement of ICD-10 implementation.

No lack of points of view

Finally, on April 17, the Department of Health and Human Services (HHS) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register to propose a one-year delay to the implementation of ICD-10 until October 1, 2014. Prior to the release of the NPRM, policymakers and thought leaders weighed in with a wide range of opinions as varied as: “Don’t delay!”, “Make it a 2 or 3 year delay”, “Let’s just move on to ICD-11”, “Do we even need ICD-10 or can SNOMED suffice?” (While this last idea may seem a bit radical and unlikely, we tend to agree with its potential to simplify—removing the administrative burden on providers and avoiding redundancy.)

But at this point, the length of a delay doesn’t really matter. What does matter is that delays continue for everything—ANSI 5010, Meaningful Use, ICD-10, the Sustainable Growth Rate resolution. And with each delay, the innovative doctors, vendors, patients, health systems and payers aren’t rewarded for their speed and efficiency.

I understand the thoughtful arguments of advocates on all sides and I know we’re collectively tackling monstrous issues. But, the culture of delay is really beginning to keep our industry stuck in a rut. The discussion seems to be increasingly focused on “When will we?” rather than “How can we?”

As always, we’d love to hear your thoughts and, more importantly, encourage you to share them with the feds, who take the comment process very seriously.

You can review the NPRM at the Federal Register. The rule also includes proposals for the adoption of a standard for a unique health plan identifier (HPID), a data element that would serve as an “other entity” identifier (OEID) and a National Provider Identifier (NPI) requirement. Comments are due no later than 5 p.m. on May 17, 2012 and instructions regarding submission can be found on page 22950 of the rule.

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