The ICD-10 Timeline: It's up for revision not destruction

Don't cancel your next ICD-10 steering committee meeting.

I know that acting Centers for Medicare & Medicaid Services (CMS) administrator Marilyn Tavenner promised to re-examine the ICD-10 timeline yesterday. But this is what she said Tuesday:

"I'm committing today to work with you to re-examine the pace at which we implement ICD-10. I want to work together to ensure that we implement ICD-10 in a way that [meets its] goals while recognizing your concerns." (via Medicare could delay burdensome rules on doctors)

That means she isn't planning to vigorously dump the ICD-10-CM/PCS requirement. Government Health IT editor Tom Sullivan doesn't see any desire to stop ICD-10 implementation either. He sees this as a move to give medical practices more time for a smoother ICD-10 transition:

"It’s incredibly unlikely that Tavenner or CMS would actually stop ICD-10 in its tracks, for a whole host of political reasons, not the least of which are potential lawsuits against the federal government by those providers and payers that have already spent millions on the conversion."

Stopping ICD-10 in its tracks would literally take an act of Congress. It's a federal law, and would require more than Tavenner's support or opposition. Which may be the reason why she's willing to re-examine timelines. This could be an attempt to appease the medical community so ICD-10 doesn't become a part of attempts to repeal President Obama's healthcare reform.

[See also: Why politicians won't care about ICD-10 implementation]

There may be a more pragmatic reason for considering an implementation delay. The HIPAA 5010 transition has been problematic.  Chantal Worzala, director of policy for American Hospital Association (AHA) said that the HIPAA 5010 disruption will complicate ICD-10 implementation.

“The AHA is supportive of the move to ICD-10 because it brings benefits for better clinical documentation, logical incorporation of codes for new technologies, and greater specificity to support accurate payment. However, changes in the environment that have occurred since ICD-10 was mandated for October 2013, including meaningful use, are putting significant pressures on hospitals. Implementing ICD-10 on schedule requires that the transition to 5010 go smoothly.” (via HCPro)

Considering that a 90-day delay in enforcement seems to have done little to ease the HIPAA 5010 transition, it looks like CMS will need stronger steps to make sure medical claim rejections and denials don't drastically increase after Oct. 1, 2013.

While those steps could address problems with the revenue side of healthcare, they wouldn't address another concern of the AMA. The cost of implementing ICD-10 compliant systems and training medical staff. Maybe an extended timeline will help healthcare providers spread the cost over more budget cycles and reduce the premium that is associated with urgency as the deadline approaches. But that would require planning. I'm doubtful delays will  inspire strategic planning. The best hope for cost reduction would be the emergence of innovation that reduced the upfront costs of compliance.

But as I write this, the CMS is preparing the rule-making process that will lead to something. No one knows what that will be. But since Tavenner made this promise to the AMA National Advocacy Conference, I'm expecting something significant. Anything less would be insulting - which is not a good strategy considering she has a U.S. Senate hearing on her appointment coming up.

As many healthcare information technology writers, I'm going to say keep your ICD-10 initiatives going. There are too many unknowns now.

Carl Natale blogs regularly at

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