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CHIME Comments on ICD-10 Compliance

May 12, 2012

The College of Healthcare Information Management Executives (CHIME) recently submitted comments to Health and Human Services Secretary Kathleen Sebelius regarding a Notice of Proposed Rulemaking to postpone the compliance date for International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10) to October 1, 2014.

In its comments, CHIME urged HHS to remain committed to ICD-10, while calling the one year delay an appropriate “middle ground” for all stakeholders.

“A longer delay would seriously disrupt ongoing efforts to convert to ICD-10,” the letter said. “And, as HHS itself recognizes, a longer delay would significantly increase the costs of converting to ICD-10. Thus, we compliment HHS for attempting to balance the interests of all stakeholders by identifying a middle ground between those who urge a longer delay, which we believe would create more problems than it would solve, and those who would prefer no change in the compliance date.”

The April notice of proposed rulemaking followed an earlier announcement by the Secretary that a delay was imminent. In response to that announcement, CHIME wrote to HHS Secretary Sebelius in February, urging HHS “to move quickly and decisively in setting a new compliance date for converting to ICD-10.” In its letter, CHIME said a prolonged delay to ICD-10 implementation, or more specifically, prolonged uncertainty about the timing and details of a delay, would create more problems than it would solve.

“We compliment HHS for the timing of this announcement and for their prompt consideration of the issue,” said Sharon Canner, CHIME’s Senior Director of Advocacy. “Many organizations have made, or are planning for, substantial investments in technology, training and education. The ICD-10 code set will also introduce a new level of data granularity for doctors and hospitals that will ultimately lead to better outcomes.”

CHIME also complimented the unified approach proposed by HHS to ensure that all providers have the same compliance date. For the conversion to ICD-10 to proceed smoothly, CHIME recommended that all segments of the provider community be in lockstep regarding conversion timeframes. However, if HHS decides to entertain different ICD-10 compliance deadlines for different covered entities, CHIME said it would be most useful to set an earlier compliance date for health plans (payers). “[A] consistent compliance date across the provider community and an earlier date for payers would make the delay much more meaningful,” the comments said.


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