On April 17, 2012 the Department of Health and Human Services (HHS) published a proposed rule that would delay, from October 1, 2013 to October 1, 2014, the compliance date for the International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10). HHS is seeking comments by May 17.
The proposed rule extends the deadline for use of ICD-10 code sets used in claims management and medical billing from October 1, 2013 to October 1, 2014, responding to providers concerned with the difficulty of implementing the new edition in the time provided. AHIMA and HIMSS are urging us to “stay the course” with our implementation planning. I agree.
Payers and Providers do not always have alignment of their own internal business and IT. Payers and Providers are not always in agreement with each other’s medical policy that will be used to defend a GEM. Payers and Providers are not always in agreement with each other’s perspective of benefit and reimbursement. Now let’s scale up from 17,000 ICD-9 codes to 155,000 ICD-10 codes…
The clock is ticking, and we’re still trying to define neutrality before we can even start to build processes to verify neutrality, and then we need to re-contract…
The Workgroup for Electronic Data Interchange (WEDI), an industry advocacy organization, conducted the survey in February and has submitted results to the Centers for Medicare and Medicaid Services (CMS). Based on the premise that ICD-10 impact assessments should have been completed in 2011, the WEDI survey results find:
- Nearly half of providers did not know when they will complete the impact assessment;
- More than a third of insurers had completed their impact assessment and a quarter of them were less than halfway done;
- One-third of providers expected to begin external testing in 2013 and one-half did not know when the testing would start;
- Most insurers do not expect to begin external testing until 2013; and
- About half of surveyed vendors were less than halfway through with their product development.
In order to start making sense of the ICD-9 to ICD-10 code variability risk, payers and providers must consider the following:
- Need for process to evolve medical policy to defend the clinical equivalency mapping of ICD-9 and ICD-10 codes ongoing
- Need for identification of ICD-9 codes within software application logic, then remediate or replace systems as required
- Need to end-to-end claim adjudication, benefit assignment and reimbursement variability testing as foundation for Payer/Provider re-contracting
Internal Business and IT need to get along. This is not typical SDLC. Testing sooner rather than later will allow for the re-introduction of test results within each iteration of process refinement. Organizations need to embrace collaborative and dynamic requirements management.
Organizations need to pick partners wisely. You can’t outsource accountability for compliance through vendors and hosted solutions.
Adjudication, benefit assignment, reimbursement schedules and re-contracting can happen later. Let’s make sure we don’t miss the mark on our assessment of clinical equivalency. Medical policy will provide context for defending our GEM, but we’ll still need to verify through testing. Even though HHS has proposed a 1 year reprieve, Payers and providers need to get to the table asap.