The Department of Health and Human Services (HHS) announced on January 15 the final regulation to replace the ICD-9-CM code sets now used to report healthcare diagnoses and inpatient procedures with the more advanced ICD-10 code set currently used in other nations. The final regulation will implement the ICD-10 code set two years later than HHS initially proposed: October 1, 2013.
The new timeline comes as welcome news to the industry, which feared that the original proposed implementation date of 2011 wouldn't give organizations enough time to prepare for the change.
Gloryanne Bryant, BS, RHIA, RHIT, CCS, senior director of coding and health information management (HIM) compliance for Catholic Healthcare West (CHW) in San Francisco, says CHW's recommendation was that an implementation date should have "at least three complete years, and because the implementation date would come out in January, we would foresee that moving [implementation] ahead would make more sense for everybody. So I'm pleased with the dates in the Final Rule."
Dan Rode, MBA, CHPS, FHFMA, vice president of policy and government relations for The American Health Information Management Association (AHIMA) in Washington, DC, agrees. "It certainly gives people plenty of time to implement and do the testing. On the other hand, it's not a reason to think that we can sit by for a while until we get closer to 2013. The concerns that we've raised about what has to be done over the next few years are still in front of us."
"We've got an extra year, so let's use it wisely," he says.
The delay in implementation did cause some mixed feelings. Jennifer Avery, CCS, CPC-H, regulatory specialist with HCPro, Inc. in Marblehead, MA, admitted to some excitement over the proposed 2011 date. "I'm sad in a way," she says. "This gives us a little more time to prepare. At the same time, I can't see why prolonging it will make it any better."
Nearly 30 years old, ICD-9-CM will run out of possible code combinations within a year. The present code set includes 17,000 codes, while ICD-10-CM includes more than 155,000 possible code combinations. This greater number of combinations allows ICD-10-CM to expand and keep up with new diagnoses and inpatient procedures. According to a statement on the AHIMA Web site, the United States is virtually the last industrialized country to adopt ICD-10-CM.
A second final rule issued concurrently with the ICD-10 final rule states the pending adoption of the X12 data standard, Version 5010, which includes updated standards for claims, remittance advice, eligibility inquiries, referral authorizations, and other administrative transactions that will take effect January 1, 2012. The current X12 standard, Version 4010/4010A1, cannot accommodate the use of ICD-10 code sets, making this change crucial. The second final rule also references Version D.0 for pharmacy transactions and NCPDP Version 3.0, a standard for the Medicaid pharmacy subrogation transaction.
Small health plans have an additional year to adopt 5010 and must be compliant with Version 3.0 by January 1, 2013.