When the Centers for Medicare & Medicaid Services (CMS) gathered public comment on the proposed rule to delay ICD-10 compliance, it considered four options.
In the final rule, it addressed the following options:
- Keep to the Oct. 1, 2013, deadline.
- Mandate an Oct. 1, 2013, compliance date for ICD-10-PCS but delay the compliance date for ICD-10-CM.
- Leapfrog ICD-10 implementation for ICD-11.
- Mandate a uniform compliance deadline for ICD-10.
These options were advocated in the public comments and CMS addressed them in the following manner.
Keep the original deadline
Commenters who wanted the 2013 deadline to stand cited:
- Healthcare organizations and individuals invested significant money and resources into meeting the deadline. A delay would penalize them.
- The delay would prevent the healthcare industry from the benefits of the data generated by using ICD-10 codes.
- Another delay would incentivize procrastination and make it less likely procrastinators will be ready for an extended deadline.
CMS acknowledged those points but considered the disruption created by unprepared entities to be more costly than the problems cited in comments.
Split the compliance deadline
ICD-10-PCS implementation in an inpatient setting was recommended as a way to take advantage of needed granularity in procedure codes. It must not have been a popular option because commenters cited increased complexity and costs of maintaining dual coding systems.
CMS agreed that separate deadlines for ICD-10-PCS and ICD-10-CM compliance would have been too costly and disruptive.
Wait for ICD-11
The American Medical Association isn't the only group in love with ICD-11. Commenters advocated skipping ICD-10 implementation because of many reasons in a paper supporting the ICD-10 implementation delay. While the paper did extol the virtues of the ICD-11 code set, it didn't advocate skipping ICD-10 implementation.
About the best reason in the comments for leapfrogging into ICD-11 implementation would be to get in sync with the rest of the world.
But CMS cited extended timetables for modifying ICD-11 codes for use in the United States and the opportunity costs of using the limited ICD-9-CM code sets for an extended period of time.
Delay ICD-10 compliance for one or two years
That was basically the debate within CMS. Many commenters preferred a two-year or more delay to give all healthcare organizations -- including non-covered entities -- enough time to implement, train and test.
In the end, CMS chose a one-year delay as the best compromise to cause the least disruption:
"We believed a 1-year delay achieves a balance between the needs of those who have already taken the initiative to plan for one-time compliance with ICD-10 and the need for other entities to have additional time to become ICD-10 compliant. While not without additional costs, a 1-year delay, to October 1, 2014, represents what we consider to be a reasonable compromise. Short of maintaining the October 1, 2013 date, delaying ICD-10-CM and ICD-10-PCS by one year does the least to disrupt existing implementation efforts, while affording the small provider community an additional year to become compliant."
While CMS explained its reasoning clearly in the final rule, don't expect it to be the final argument. Most of the reasons outlined are not new. They haven't persuaded ICD-10 critics so far.