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AHIMA has said it before, and it is saying it again. Delaying the ICD-10 deadline is not a good idea. The College of Healthcare Information Management Executives (CHIME), however, called the one-year delay an appropriate “middle ground” for all stakeholders while urging HHS to remain committed to the new code sets.
AHIMA filed a comment letter Wednesday with the Department of Health and Human Services’ leaders in response to a section of a proposed rule that addresses “Change to the Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets.”
In its letter, AHIMA continues to recommend there be no delay in the ICD-10 compliance deadline. Since a delay is likely, AHIMA leaders said the association will continue to work with HHS and the healthcare industry to ensure the delay is as short as possible, preferably not more than one year.
“ICD-9 is antiquated and no longer adequately meets the challenge of a 21st century healthcare system,” said AHIMA CEO Lynne Thomas Gordon. “ICD-10 should be implemented in a timely manner, and AHIMA is ready to continue assisting the healthcare community to prepare for the transition. We also encourage advance testing of the ICD-10 codes to be sure there are no further delays in the implementation deadline.”
AHIMA and the health information management (HIM) professionals who comprise its membership are well qualified to respond to the proposed rule, Thomas Gordon said. Many AHIMA members are on the frontlines and work directly with the classification systems impacted by these rules and were involved in the development and maintenance of the existing code set and the development of ICD-10.
The letter calls attention to the classification system as more than a claims and billing mechanism. They are critical to the care and diagnosis information that can be synthesized and used for communicating issues of severity, quality and provide better healthcare for the individual patient and the community. For instance, AHIMA noted, the ICD-10 codes significantly expand the ability to document and detail incidences of domestic violence. As a result, health officials can enhance detection and treatment and develop more proactive steps to prevent domestic violence.
“ICD-10 is the foundation for other critical national healthcare initiatives such as meaningful use, value-based purchasing, payment reform, quality reporting and accountable care organizations,” said Dan Rode, AHIMA vice president for advocacy and policy. “Without ICD-10, the value of these other efforts is greatly diminished.”
A delay of more than one year would cause additional confusion for colleges and universities as to what they should be teaching, AHIMA executives noted. Students already have been trained in ICD-10 and are forced to use ICD-9-CM when they enter the work force.
In its comments, CHIME agreed with AHIMA about the timing. “A longer delay would seriously disrupt ongoing efforts to convert to ICD-10,” CHIME’s letter explained. “And, as HHS itself recognizes, a longer delay would significantly increase the costs of converting to ICD-10.”
The April notice of proposed rulemaking followed an earlier announcement by Sebelius that a delay was imminent. In response to that announcement, CHIME wrote HHS in February, urging the agency “to move quickly and decisively in setting a new compliance date for converting to ICD-10.”
CHIME also supported the unified approach proposed by HHS to ensure that all providers have the same compliance date. Should HHS decide to entertain different ICD-10 compliance deadlines for different covered entities, however, CHIME said it would be most useful to set an earlier compliance date for health plans. “[A] consistent compliance date across the provider community and an earlier date for payers would make the delay much more meaningful,” CHIME wrote.
Finally, CHIME recommended that HHS move steadily towards its proposed compliance deadline for ICD-10 and dismiss calls to “leapfrog” from ICD-9 to ICD-11.
“Everyone in the healthcare IT world is working against numerous deadlines,” said George Hickman, executive vice president and chief information officer at Albany Medical Center in Albany, N.Y. “But it’s vitally important for those of us planning, budgeting and implementing these projects to know when those deadlines are coming. ICD-10 is a major undertaking, and we encourage HHS to be vigilant in monitoring industry readiness, while making clear its intentions regarding the final compliance date.”
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