ICD-10 Deadline Delay: No Time for a “Wait-and-See” Approach To Compliance

As is widely known by now, the deadline for compliance with ICD-10 was pushed back one year to 10/1/14.  Health plans should be using the extra time to continue on their path to transition; and some should even accelerate efforts to implement the new medical billing codes.

There’s a lot of work to do:  ICD-10 implementation is a complex and costly undertaking involving remediation of systems and business processes touching nearly every part of a health care organization. At this crucial time in the switchover to ICD-10, however, most health plans are slowing down — not speeding up. Some have even shut down the work altogether and have reassigned resources away from ICD-10 initiatives to new IT projects.Mary Singer


The pervasive strategy, particularly among senior leaders in health care, is to “wait-and-see.” Many think that if the HHS pushed the deadline back once then they will do it again. Others are stalled, still grappling with the repercussions of the ICD-10 delay.

“Wait and see” is never a smart strategy. It increases the risk of non-compliance for health plans. Now that the 2012 election is oMichael Saulsver, the health care industry will need to move forward with reform. Costs in the United States health care system are unsustainable. America’s health care system requires transformational change to provide all health care participants with broader access and choice, improved quality and reduced health care costs. To truly bring our complex health care system into the 21st century, we must adopt new approaches and technologies that yield better health outcomes by improving connectivity, care delivery and use of public resources.

ICD-10 is foundational to the transformation of our health care system.  It provides for more detailed information that will drive analytics that support better disease diagnoses, more targeted treatments and improved patient outcomes.

HHS appears committed to avoiding further delay in the ICD-10 compliance date, acknowledging that a longer delay would significantly increase the costs of converting the codes.

So, how can payers reboot efforts? For one thing, ICD-10 project managers must reengage senior leaders on the new deadline, and secure commitment again from the top of the organization. Resources need to be assigned back to ICD-10 conversion. ICD-10 assessments must be refreshed with the new timetable in mind and foundational translation maps built by no later than January 2013.

Testing both internally and externally should be targeted to begin by late 2013. It should continue throughout the process to identify potential changes to coding maps – before systems and end-to-end testing – so plans can identify financial and operational outcomes that affect the business process.  Testing early and often is the key to mitigate financial, clinical and operational risks while optimizing business processes to take advantage of the benefits that can be derived from the transition to the ICD-10 coding system.

Payers, perhaps more than any other health care stakeholder, are expected to lead the industry on testing of ICD-10 transactions.  As we learned from the implementation of the HIPAA 5010 transaction set, testing is critical to a successful outcome for both the provider and payer communities. Again, so much work left to do with so much at stake. There is no time for a “wait-and-see” approach to ICD-10.

ICD-10 Assessment, Remediation & Optimization Timeline

Mary Singer & Mike Sauls

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