The Medical Group Management Association (MGMA) wants the Department of Health and Human Services (HHS) to do more than delay ICD-10 implementation.

In a March 1 letter to HHS secretary Kathleen Sebelius, MGMA president and CEO Susan Turney outlines some steps that should be added to the ICD-10 timeline that would inject some due diligence to the process.

[Download: MGMA letter to HHS with ICD-10 recommendations]

Those steps would be:

1. "Complete a comprehensive cost benefit analysis."
2. "Pilot test ICD-10."
3. "Analyze the administrative and financial impact of overlapping initiatives."
4. "Evaluate additional code set approaches."
5. "Stagger implementation dates."
6. "Develop appropriate crosswalks."
7. "Require Certification."

Note nowhere in this letter does the MGMA express any opposition to ICD-10 implementation. Apparently they think it may be a perfectly fine code set. But let's make sure first with cost benefit analysis, evaluations and tests. And maybe we should look at other options.

It pretty much sounds like a plan to delay ICD-10-CM/PCS until dies of old age.