2012 Conference Preview: On a Clear Day I Can See ICD-10 . . . Or Can I?

By Sparkle Sparks,
OASIS Answers

Join Sparkle at conference for “Prep for ICD-10-CM for Home Health Agencies” on July 26. She will also co-present Blueprint for OASIS-C Accuracy on July 22-23. Click here to check out the session summary in the conference brochure!

Following the continuing saga of the implementation of ICD-10 is like playing a game of “red light, green light.” Remember that? Someone yelled “green light” and frantic motion was set in high gear. Then someone yelled “red light” and you had to freeze, no matter how uncomfortable and hard to maintain your position was. If you inadvertently moved, you were out of the game.

Many people aren’t aware that the 2013 target date was actually pushed back from 2011. Now it appears that the target has, once again, been postponed to October 2014.

We were first alerted to this latest possible delay back on February 16 of this year. Health and Human Services’ Secretary Kathleen Sebelius announced that, “HHS will initiate a process to postpone the compliance date by which certain health entities have to comply with ICD-10.” This pronouncement created a few questions like, “what does process to postpone mean?” and, “certain entities – which ones are these?”

While we patiently awaited the answers to these questions another announcement was released on April 9, 2012. This time Kathleen Sebelius announced a proposed rule that would delay the compliance date for ICD-10 from October 1, 2013 to October 1, 2014. And while it is anticipated that the final rule would be announced this month as of today, June 16, 2012, the silence is deafening.

So while we wait for further direction what, if anything, should we be doing? The advice from one of the Cooperating Parties in charge of both ICD-9 and ICD-10, the American Health Information Management Association (AHIMA), “urged the healthcare industry to remain vigilant in their ICD-10 transition efforts despite an implementation delay.”

In the June issue of the Journal of AHIMA it was noted that while some timetables might need to be adjusted, the proposed delay should not be used as an excuse to procrastinate. AHIMA pointed out that even HHS is encouraging providers to continue on with the implementation schedules that they already have in place. There are some tasks that need to be completed anyway. Nothing is to be gained by waiting until the last minute. So agencies need to keep marching forward with organizational changes.  But what should coders be doing at this point?

This same article discussed academia’s handling of coding curricula. According to AHIMA most facilities plan to offer multi-code set (both ICD-9 and ICD-10) training until the year before the new implementation deadline.  At that point they will switch to teaching only ICD-10. What can we take away from this? Coders still need to remain vigilant and educated regarding ICD-9.  Waiting until about a year prior to implementation to actually learn how to assign ICD-10 codes is another good idea. This practice is consistent with an observation that CMS made in a Medlearn Matters article last year. It stated that while it is not too soon to become familiar with the organization and structure of the ICD-10 code set, new features of the system and how the codes look; it is too early to actually learn how to assign ICD-10 codes.

It should be noted that the delay in ICD-10 has not affected the deadline for providers to comply with Version 5010. Version 5010 refers to the standards that HIPAA-covered entities must use when electronically conducting certain health care administrative transactions, such as claims, remittance, eligibility, and claims status requests and responses. To be compliant organizations must use Version 5010 to send and receive claims and all other HIPAA-adopted electronic transactions starting January 1, 2012; however, CMS has implemented an enforcement discretion period, which is in effect until June 30, 2012. And that is right around the corner.

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