With the clock ticking toward an October 1, 2015 compliance deadline for ICD-10, Tennessee Rep. Diane Black recently introduced a bill, HR 2247, that would require a transition period for the changeover from ICD-9 codes. Rep. Black’s bill would not stall the October 1 compliance date, but it would require the U.S. Department of Health and Human Services (HHS) to provide transparent end-to-end testing of the new system to certify that it’s fully functional. According to the legislation, during the testing period and for 18 months following HHS certification, the Centers for Medicare and Medicaid Services (CMS) would be prohibited from denying claims “due solely to the use of an unspecified or inaccurate code.” Essentially, that means CMS would have to accept, process, and pay claims that are submitted with either ICD-9 or ICD-10 codes.
Two weeks prior to the filing of Rep. Black’s legislation, Texas Rep. Ted Poe introduced HR 2126, which would simply prohibit HHS from replacing ICD-9 until the Comptroller General completes a study “to identify steps that can be taken to mitigate the disruption on health care providers resulting from a replacement of ICD-9.” Both pieces of legislation have been referred to the House Committee on Energy and Commerce and the House Committee on Ways and Means.
Oct. 1, 2014 is the deadline for ICD-10 conversion. However, according to a survey from the Workgroup for electronic data interchange, 8 out of 10 practices have not begun testing and only half have begun the initial steps of impact assessment. Some attribute these delays to their IT vendors not being ready; 40% of vendors said their products won’t be ready before 2014. There has been discussion about The Centers for Medicare and Medicaid Services (CMS) possibly delaying the deadline again or an “enforcement-free” period of 6 months, but CMS has resisted that idea.
On a more positive ICD-10 note, Sutter Health of California is planning on going live this May, a result of its 3-year planning efforts. The May launch will give Sutter doctors a five-month test period before the deadline. Danielle Reno, Sutter’s ICD-10 program director said, “We won’t be submitting claims to payers in ICD-10, but we will turn it on, and physicians will be able to use it.” Another company testing its ICD-10 plans is North Carolina Healthcare Information & Communications Alliance (NCHICA). Holt Anderson, executive director at NCHICA, ran a test pilot with some of the best coders, and there were still significant concerns about accuracy. Using “dual coders” who coded in both ICD-9 and ICD-10, only 55% of the transition scenarios were accurate in the first wave of testing.