On April 1, 2014, President Obama signed H.R. 4302, Protecting Access to Medicare Act of 2014. Within this bill there is an ICD-10 delay provision which states:
“The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD-10 code sets as the standard for code sets under section 1173(c) of the Social Security Act (42 U.S.C. 1320d-2(c)) and section 162.1002 of title 45, Code of Federal Regulations.”
While the industry awaits news from CMS, we at Freed Associates are working directly with institutional and professional providers, IPAs, payers, and vendors to determine the disposition of existing ICD-10 work and re-planning efforts. In particular, for providers, it will be important to review training plans for clinician and coding personnel, testing plans with external trading partners, and remediation work around EMR and billing systems. Decisions around moving forward as planned, postponing, continuing at a slower pace, or cancelling activities will be important for each organization to determine for itself. It may also make sense to reconsider increasing the scope of the project to include additional components, such as computer-assisted coding or more comprehensive clinical documentation improvement solutions.
For payers, some key areas of consideration will be to review all applications that are related to EDI intake, benefits mapping, claims, and pricing systems, and identify all instances where the previous deadline date was included in the system logic. Provider contracts may need to be reviewed, as will testing plans with clearinghouses and providers. It will be important for all project teams to revise their communications plans, ensuring that all internal and external stakeholders are aware of steps that the project team is taking in light of the delay.
Developing a short and medium term refocus plan will entail taking time at a leadership level to complete a comprehensive review, and decide what impact the project changes will have to 2014 and 2015 budgets. Consideration should be given to how to shift 2014 costs to 2015 while minimizing the overall multi-year spend and duplication of efforts.
If you have any questions regarding the impact of the ICD-10 delay on your organization, please feel free to contact Freed Associates at 510-525-1853.