It's no surprise that the state of the HIPAA 5010 transition is something of a mess. The potential for slowed or even stopped claims reimbursements is understood. And the inevitable ripple effects on health IT are not so clear. What with that increasingly louder clock ticking in the back of the healthcare industry's collective head, a question: As the Jan. 1, 2012 compliance deadline approaches, should providers and the federal government devise contingency plans for HIPAA 5010? "As much as I like deadlines and people being held accountable, I think it would be a dereliction of duty for (the Centers for Medicare & Medicaid Services) to not come up with some sort of contingency plan for HIPAA 5010," said Steve Sisko, an analyst and technology consultant focused on payers and ICD-10. Sisko is hardly alone in thinking that a backup plan will be necessary. Testifying late last month before the National Committee on Vital Health Statistics, the Medical Group Management Association said that "as of early June, very few practices have instituted external testing, and this could lead to a backlog of test requests in the last few months of the year."