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The Future of ICD-10

—April 15, 2015
The Future of ICD-10
By Michele Hibbert, Vice President, Information Management & Client Services, Mitchell

Today the medical billing/coding industry seems to be in the clear with regard to any further postponement of ICD-10 in the United States. We have adopted the mantra for “one day at a time” which essentially is a waiting game for another delay in the implementation. Today, we know the ICD-10 planned implementation has been scheduled for October 1st 2015. Having our ear to the industry, lobbyists, associations and news organizations monitoring the implementation, we have learned a valuable lesson that “today” only means one date in history. What drives us insane is the fact that “tomorrow” can bring a complete reversal and change in plans for this valuable classification system implementation. What we know today is that there is nothing stopping ICD-10 from being implemented except for tomorrow.

In the P&C Industry, the payers are non-covered entities under HIPAA. Being a non-covered entity means you are not required to use ICD-10 unless required by state regulations or compliance mandates at the state level. The level of complexity for the P&C Industry is the realization that every state is it’s “own country” in the ICD-10 world. In addition, the providers submitting the coded bills ARE covered entities and required to use ICD-10 (today) effective October 1st 2015. Bottom line, being a non-covered entity as a payer means you need to work harder, there is nothing simple about trying to be part of an industry and use the same tools to insure portability of medical care when you are excluded from one of the most important mandate in quality improvement and communication of care. As an example the California DWC Regulations to amend the implementation date of ICD-10 goes through an approval process by the Office of Administrative Law every time there is a change. For the last delay the communication in part is:

“Subsequently, the U.S. Department of Health and Human Services issued a final rule postponing use of the ICD-10 until October 1, 2015, for HIPAA-covered entities. For workers’ compensation, the Administrative Director has amended the Medical Billing and Payment Guide to align the workers’ compensation ICD-10 transition date with the October 1, 2015 ICD-10 transition date applicable to HIPAA-covered entities and the broader health care sector. All workers’ compensation participants are encouraged to move forward expeditiously to prepare for the transition.”

Will the next change begin with “Subsequent to the subsequent…?” It would almost be easier for California to just have a fill in the blank space for the implementation time frame moving forward or just use words like “Today, the implementation of ICD-10 is October 1st 2015 but tomorrow it will be __/__/__.” In all seriousness, making these changes costs time, money and resource confusion in addition to the bigger implementation picture issues. There are a handful of states in workers compensation that have addressed the usage of ICD-10 and the implementation, for the most part none are preventing it from happening on October 1st 2015. In P&C if the current Medicare Fee Schedule has been adopted by the state – specifically inpatient, then ICD-10 plays a large role in billing and payment for hospital providers and keeping our eye on the current situation today will assist the industry in maintaining compliance and using this new system to benefit the care and communication for the consumers we serve.

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