As expected, the buzz surrounding ICD-10 continues to grow as we move closer to the October 1, 2015 implementation deadline.

Last week, Texas-based Republican Rep. Ted Poe, proposed the “Cutting Costly Codes Act of 2015” to block the replacement of ICD-9 with ICD-10. Now, another proposal, a more realistic and achievable one I must say, has been put forward by a fellow Republican.

The Proposed Bill

Rep. Diane Black, a former nurse, hasn’t mandated to block or delay the ICD-10 implementation. Instead, she has proposed a bill which will protect healthcare practices from penalties that result from mistakes.

The “Increasing Clarity for Doctors by Transitioning Effectively Now Act”, which fittingly abbreviates into the ICD-TEN Act, calls for more comprehensive ICD-10 testing, and an 18-month “fully functioning” grace period post-ICD-10 implementation. Before I elaborate further, it is necessary to clarify what the bill doesn’t entail.

What the bill doesn’t call for:

• No delay, blocking, or banning of the October 1, 2015 implementation
• No calls for ICD-9 codes to be used post-ICD-10 implementation

What the ICD-TEN Act will bring:

ICD-10-CM/PCS codes will be used across the country from October 1 onwards.

• The Department of Health and Human Services (HHS) must conduct comprehensive and transparent end-to-end testing to ensure that the new coding system is “fully functioning”.
  • “Fully functioning”: The percentage of claim acceptances with ICD-10 codes should not be less than the percentage of claim acceptances with ICD-9 codes (for the same period corresponding to the previous year)
  • This means that the HHS must closely monitor the country’s reimbursement process, to ensure that it is not adversely affected with the introduction of the new codes.
  • For this, each vendor participating in the Medicare fee-for-service (FFS) program, must also have access to end-to-end testing.
• Within 30 days, the HHS must report:
  • Either that the new code set is fully functioning
  • Or its plan to make the ICD-10 standard fully functioning
• No ICD-10 claim denials “solely due to the use of an unspecified or inaccurate sub code” during the implementation period
  • An implementation period that begins on October 1, 2015
  • The implementation period ends 18 months after the ‘fully functioning’ certification of the new codes by the HHS. (Note: not 18 months after the October 1 implementation date)
  • The bill would not shield healthcare professionals from casual-routine mistakes that result from the code updates.

CureMD’s stance on the ICD-TEN Act

We’ve been regularly posting resources, news, and updates about ICD-10 for over two years now. Many physicians have inquired about our stance on ICD-10. Well, here it is:

Let’s start with the delay in 2014. Back then, the delay was a good move by the CMS. Not only did it warn the industry, that they needed to prepare, but it actually provided them the time for preparation.

However, the code updates are a necessity, and we can’t continue to shy away from them forever. So yes, we do support the ICD-9 to ICD-10 updates.

Having said that, we are sympathetic towards the plight of small independent practices. A transition of this magnitude should be accompanied by some government sponsored safety net to protect independent practices. This will ensure that they learn the new coding language without disruptions to their ability to deliver care.

Till now, the proposed ICD-TEN Bill seems to be the most appropriate solution. It will provide practices with the flexibility and time required to master ICD-10 without suffering revenue losses. Do you agree?