ICD-10 Timeline: Public comment has started without a CMS proposal

Carl Natale
by Carl Natale

The longer the Centers for Medicare & Medicaid Services (CMS) delays delaying the ICD-10 implementation deadline, I wonder how useful the rulemaking process will be.

The idea is to publish the new deadline(s) as a proposed rule in the Federal Register. Then collect public comment on it for 60 days before making a final decision.

Since this is the Internet age, public comment is being registered without a federal forum. A recent example is Zirmed's online petition asking "Should CMS Stop, Go, or Slow Down Regarding the Transition to ICD-10?" You can register your opinion on the appropriate opinion. No word yet on how that feedback is going.

I wonder if the people at CMS will do just as well if they just monitor the Internet for 60 days.

Meanwhile, my poll shows some movement in opinion (How should the CMS adjust the ICD-10-CM/PCS timeline?):

  • 73 percent don't want any change at all
  • 13 percent want to leapfrog ICD-10 coding and implement ICD-11 coding
  • 13 percent favor some sort of delay
  • 2 percent want a HIPAA-like delay of enforcement

This adds up to 101 percent because of rounding. One commenter questions validity of the survey:

"Many, perhaps most of your readers have a vested interest in ICD-10 either as professional coders, ICD-10 project staff, or similar."

"If true, the outcome of your survey was as predictable as one that asks tax attornies and accountants how they feel about simplifying the IRS code."

I don't think there is any perhaps about it. My readers are deeply involved in the ICD-10 transition. I'm not surprised at all they overwhelmingly favor keeping Oct. 1, 2013, as the deadline. (I am surprised that the ICD-11 option is gaining traction.)

When the American Medical Association (AMA) first started this vigorous opposition, I asked "Now that the AMA has promised to fight ICD-10 implementation, will they succeed?" The results were less than surprising and this is how I explained:

"So far, 81 percent of the 36 respondents said no way. And the discussion in our ICD-10 Watch group on LinkedIn vouched for the integrity of the deadline and usefulness of ICD-10."

"But that's not enough to declare the AMA's fight over before it starts. Asking this question is a bit like asking a football fan if his or her favorite football team will win the Super Bowl. There's a bit of bias here. People are deciding the fate of ICD-10 based upon their assessment of the merits. Maybe I'm guilty of that."

So yes the bias is a bit predictable. Speaking of predictable, this was the post that has me declaring "Now I'm not so sure CMS is going to keep the Oct. 1, 2013 deadline written in stone."

I'm just saying.

ICD-10 Benefits – Where are they?

A blogger named John asks a good question. Where are the concrete examples of the benefits of ICD-10 coding? (EMR and HIPAA)

HIPAA 5010 Transition Problems

The Healthcare Billing and Management Association (HBMA) has a report on the major problems from the HIPAA 5010 transition that lists the major causes of rejections, denials and delays.  According to this post, healthcare organizations seemed to have worked out the problems mostly. There are still isolated problems. But clearinghouses seemed to have had smoother experiences. (GroupOne Health Source)

How to find out how much ICD-10 implementation will affect your organization

We keep saying that ICD-10 is a major change to healthcare providers. This post rounds up resources that will help you figure out just how much change there will be. (ICD10 Watch)

The keys to legacy AR: Unlocking buried treasure in preparation for ICD-10

Simon Hughes cites an example of how ICD-10 coding has the ability to impact your entire healthcare organization - not just medical billing:

"One important issue that has come to light in the transition to next-generation clinical systems is the fact that these newer systems do not interface with older, legacy accounts receivable (AR) systems"

Many organizations plan to upgrade the AR systems (and I assume any other system that doesn't interface well) now. It also helps to explain how the ICD-10 transition can become so costly and disruptive. (Healthcare Finance News)

Don’t Let the Buzz Slow Down Your ICD-10 Plans

The conventional wisdom is that you shouldn't count on the ICD-10 deadline changing. No one knows how much extra time - if any - there will be. Lorraine Schnelle suggests reviewing all your documents and forms now. If you haven't started your ICD-10 transition, figuring out what needs to change is a good place to start. (The BridgeBlog)

Federal government releases SNOMED to ICD-10 map

The National Library of Medicine (NLM) released a preview version of a SNOMED CT to ICD-10-CM map. The maps are designed to automatically generate ICD-10-CM codes from clinical data entered into electronic health records (EHRs). (ICD10 Watch)

Guest Post: Can technology streamline change?

Chris Cashwell of Nuance Healthcare explains how to leverage technology to lessen the impact of ICD-10 implementation on medical practice workflows. (ICD10 Watch)

ICD-10-PCS guideline A11 puts onus on coders

Michelle Leppert explains that medical coders may not be able to assign the proper ICD-10-PCS codes given the current state of clinical documentation. (ICD-10 Trainer)

ICD-10-CM Delay… Prolonging the Distraction

John Carter, vice president of Apelon, is a big fan of ICD-11 code sets and SNOMED-CT. But he's not a fan of leapfrogging ICD-10 coding and going right to ICD-11 implementation. It would be too complicated. (Healthcare Standards)

Experts offer 5 ways to cut IT costs

Michelle McNickle rounds up what healthcare IT experts have to say about saving money on major IT projects:

  1. Think practically.
  2. Look for creative solutions.
  3. Don't underestimate the cost savings associated with training.
  4. Think enterprise-directed IT.
  5. Consider investments and their cost savings in the long run

(Healthcare IT News)

Health IT - Best Practices to Minimize Cash Flow Disruptions Resulting From ICD-10 Implementation

Frank Costello has nine tips that can help medical practices protect themselves from disruptions in reimbursements. (EzineArticles)

A Chance to Lead

The challenges of ICD-10 implementation is an opportunity for the IT department to take on a leadership role. (H&HN Daily)

What Do You Do Regardless? Five ICD-10 Steps to Continue

There are five things that healthcare providers can do to prepare for ICD-10 implementation that can improve the organization even if the deadline is delayed. (Coding Compliance Blog)

How HIMSS 2012 conference will shape the rest of the year

Brian Eastwood sums up the HIMSS12 highpoints. He has an interesting point about how iPads are bound to be the preferred EHR device. (Health IT Pulse)

ICD-10: AMA Decision Tries to Avoid the Inevitable – and Will Likely Fail

Paul Weygandt argues that the AMA isn't serving its constituency by vigorously opposing the ICD-10 transition. (Clinical Integration for Quality Blog)