October 1st, 2015, is the deadline for healthcare providers to implement the twice-delayed ICD-10 code set, federal officials confirm.
HHS will release the final rule, Administrative Simplification: Change to the Compliance Date for the International Classification of Diseases, 10th Revision (ICD–10–CM and ICD-10-PCS) Medical Data Code Sets, in the Federal Register August 4.
The one-year delay will allow US healthcare providers to reap the benefits of ICD-10 as soon as possible and is also the least expensive option, HHS stated in the final rule.
Hospitals Likely to Outsource ICD-10 at Launch
CMS was adamant about keeping October 1, 2014, as the compliance date. However, Congress passed H.R. 4302, "Protecting Access to Medicare Act of 2014" in March. The bill included this statement:
- The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD–10 code sets as the standard for code sets under section 1173(c) of the Social Security Act (42 U.S.C. 1320d–2(c)) and section 162.1002 of title 45, Code of Federal Regulations.
President Obama signed the bill into law April 1 and as a result, HHS was forced to move the ICD-10 implementation date.
First mention of a new date
HHS first stated October 1, 2015, as the new implementation date in the IPPS proposed rule, released April 30. In several places in the proposed rule, HHS referred to October 1, 2015, as the ICD-10 implementation date.
One day later, CMS issued this statement:
- On April 1, 2014, the Protecting Access to Medicare Act of 2014 (PAMA) (Pub. L. No. 113-93) was enacted, which said that the Secretary may not adopt ICD-10 prior to October 1, 2015. Accordingly, the U.S. Department of Health and Human Services expects to release an interim final rule in the near future that will include a new compliance date that would require the use of ICD-10 beginning October 1, 2015. The rule will also require HIPAA covered entities to continue to use ICD-9-CM through September 30, 2015.
Although HHS originally planned to release an interim final rule with the new compliance date, it ultimately sent a final rule to the Office of Management and Budget for review June13.
Stakeholders and the public can comment on an interim final rule even though it goes into effect immediately. The rule can then be amended based on those comments.
However, HHS decided to release the new implementation date through a final rule, when comments are not accepted. HHS is permitted to waive rulemaking requirements if it finds that notice and comment procedures are impracticable, unnecessary, or contrary to the public interest. HHS believes "waiving normal notice and comment rulemaking requirements is justified because covered entities need to know how to proceed with respect to ICD-9-CM and ICD-10 now, or they will not have adequate time to prepare to accurately submit, process, and pay for healthcare claims."
Industry readiness
The healthcare industry seems to be using the delay to its advantage.
In a June 2014 survey of 5,000 AAPC members, 75% of respondents reported that they are making significant progress toward preparing for ICD-10 implementation.
The survey also indicated that approximately 25% of those surveyed had completed all necessary ICD-10 training; 13 % indicated that they were prepared for the October 1, 2014 implementation date; and 23% were actively testing with their ICD-10 vendors when ICD-10 was delayed in April.
A whopping 68% of the respondents to a survey conducted by Edifecs, eHealth Initiative (eHI) and AHIMA in June are planning additional training during the delay.