April 24, 2012 | | Comments 0
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Note from the Instructor: ICD-10 Delay

This week CMS published a proposed date for the delay of ICD-10 implementation. They are proposing to delay from October 1, 2013 to October 1, 2014.  This is only a proposed rule and arguably the delay could be even longer if sufficient comments were submitted to convince CMS of the need for a longer delay. The timeframe is unlikely to shorten, however, because of the inpatient coding and payment systems, which are run on an annual cycle beginning in October of each year.

The delay of ICD-10 implementation has been somewhat controversial with provider groups. The delay was announced as part of another administrative simplification proposed rule related to unique identifiers for health plans. Recall that the implementation of ICD-10 is a part of the administrative simplification rules that specify which code sets are used for healthcare transactions.

The delay was originally announced in February, but no official delay timeframe or date was specified at that time. The delay had the support of the American Medical Association (AMA), who had been lobbying for some kind of delay for some time. However, others including the American Health Information Management Association (AHIMA) did not want any kind of delay because of the work and expenses already spent by larger organizations such as hospitals and health systems with the 2013 implementation date in mind.

This further delay puts us even further behind the rest of the world in diagnosis coding. While we are playing around implementing the ICD-10 in 2014, an ICD-11 alpha draft is already available and a beta version will be ready to use in 2014 with full implementation said to be in 2015 or 2016.  With so much preparation behind ICD-10, it’s hard to imagine a switch to ICD-11 at this point, but it seems that to not do so means we will be going through the same pain twice: once to implement ICD-1,0 and in the not so distant future, a second time to implement ICD-11. This seems like it would create a tremendous financial burden on health providers, just to ensure we catch up to where the rest of the world will already be.

Nevertheless, we are so far down the road of ICD-10 implementation it’s hard to imagine a switch at this point.  AHIMA recommends providers continue with their preparations as planned to ensure sufficient time to be fully prepared, although the intense education in the last few months before the implementation to get coders proficient will need to be changed. I would recommend that providers not change their ICD-10 plans until we see a final rule in the event CMS implements a longer delay.

One last thing: I am very excited about a new product HCPro is releasing called HCPro Comply for Revenue Cycle. I will be at the upcoming HCCA Annual Compliance Institute in Las Vegas later this month doing a Lunch and Learn showcasing the product. I’m so excited about Comply for Revenue Cycle. As a former compliance officer, auditor and chargemaster coordinator, I was able to sit with the developers and give them an idea of what we’d like to see in a product like this. They also worked with more than 50 hospitals around the country during development and it really shows. The product is so intuitive and puts all the right information at your fingertips – including coding information, state regs and of course all the Medicare information. I could go on and on – and I think the folks back at HCPro are tired of me raving on, but I really am that excited. If you want to learn more, you can sign up for the Lunch and Learns at the link at the end of this week’s Medicare Weekly Update. See you there!


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Filed Under: CodingComplianceNote from the Instructor


Kimberly Hoy About the Author:

Kimberly Anderwood Hoy is director of Medicare and compliance for HCPro, Inc.

As a hospital compliance officer, Kimberly regularly provided research and guidance on coding, billing, and reimbursement issues for a wide range of hospital services. She has a particular expertise in charge description master operation, development, and maintenance. She has experience conducting billing compliance audits and internal investigations. Kimberly also has had primary responsibility for HIPAA privacy regulation compliance, including risk assessment, program development, implementation of policies and procedures, and ongoing operations.

As In-House Legal Counsel, Kimberly had oversight of expense contracting and regulatory compliance, including federal and state laws and regulations. Kimberly regularly provided legal advice on such complex topics as consents, EMTALA, Stark, anti-kickback and anti-inducement laws, physician recruiting, and tax exemption regulations.

Kimberly has served as a speaker at compliance-related conferences in the areas of compliance program effectiveness and physician education. Kimberly is an active member of the American and California Bar Associations, the American Health Lawyers Association and the Health Care Compliance Association.

Kimberly earned her Juris Doctor degree from the University of Montana School of Law, where she received the Corpus Juris Secundum Award for Excellence in Contracts. She also holds a Bachelor of Arts degree in Philosophy from Yale University.

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