The ICD-10 Final Rule

Well, we got a final rule. And, it says little in the regulation besides giving a compliance date of Oct 1, 2013 (coding for services provided on and after that date). Much better than the proposed date of Oct 2011; not as long as some others (including me) had hoped for to assure the industry gets this massive project done correctly.

HHS had quite a discussion in the preamble about comments and why they made the decisions that they did. Lots of discussion on timing. They finally decided on the 2013 date since that is what some health plans asked for, and that matches some of the NCVHS recommendations. They dismissed many provider and other organizational comments asking for more time. WEDI had recommended a specific timeline asking for six years to implement.

The relationship with the HIPAA version upgrade efforts is interesting. HHS stated several times that they expected some of the work and costs to be incurred during the version upgrade process, thereby reducing the time and cost of the ICD-10 upgrade. I don't think that was postulated in the HIPAA version upgrade regulatory discussion.

One interesting piece from the impact analysis.

If I am reading it correctly, the HHS estimates for the total costs and benefits over 15 years (Tables 6 and 7) show a net cost of the effort with a 7% discounted rate for present value. At a 3% rate, there is a net benefit.

Now, these are accounting terms and 15 year projections. However, one could argue that this is a wash, so why go through all of this effort if we are really not going to get a benefit out of it. Excellent question, and one that perhaps HHS can answer for us.

Some other issues covered in the final rule -

The date of service for inpatient hospital procedures will be considered the data of discharge, not the date of admission as some had asked for. This means that a patient entering prior to Oct 1, 2013 will have to have his/her claims coded in ICD-9 if discharge is before Oct 1, in ICD-10 if discharge is after Oct 1. This may be somewhat confusing for documentation.

HHS also stated that the final coding guidelines would be published by the end of January. As of today (Jan 27) I could not find them on either the CMS or NCHS web site.

The ICD-10 project will be a massive change for health plans and providers. Those entities looking at the 2013 date and saying "we've got plenty of time" should remember the HIPAA 1 and NPI experiences. The industry faced major hurdles on the compliance dates for those requirments. ICD-10 is much bigger, as it impacts both clinical systems (that store documentation, results, and codes) and the administrative systems. Starting the assessment process now would be a critical first step. And, for those who don't think they are aware of all of the business processes that will be impacted, give me a call. I've got lots to tell you.