The short answer…no one knows yet.

My short, best prediction…yes. ICD-10 will go into effect on October 1, 2015. There will be no more delays.

Here’s why. The AMA and other anti-ICD-10 groups were successful last year in getting Congress to secure a surprise delay of the ICD-10 implementation deadline from October 1, 2014 to this year. The winning card was that CMS had not done any end-to-end testing with providers, though it had been urged by many to do so. CMS, regardless of its confident stance, could not genuinely confirm its readiness to move forward into the world of ICD-10. But, this year, we are looking at an entirely different scenario.

CMS has taken the right step — and scheduled three end-to-end testing periods for 2015. The first round of test claims is being submitted this week, and by mid-February, we should have the preliminary results. Those results – created by real tests of real ICD-10-coded claims – will change everything, including the trajectory of ICD-10 in 2015.

If the testing goes poorly, CMS probably will have to announce another delay, and justifiably so. However, it is likely that testing will go smoothly, especially given the voluminous data CMS has gathered from providers during acknowledgment testing, and the extensive internal testing CMS has already completed.

There is strong industry support for sticking with the 2015 deadline. Many, if not most,  hospitals, health systems and insurers have invested millions in the conversion from the country’s antiquated ICD-9 coding system to the world standard ICD-10. The ICD-10 Coalition, a broad mix of influential healthcare organizations including the AHA, CHIME, HFMA, AHIMA and many major healthcare vendors, is in strong support of conversion by October 1, 2015.

Even the AMA, which in the past has based much of its opposition to ICD-10 on CMS’ lack of testing, can no longer do so — though AMA officials remain concerned about the cost of conversion, particularly for physician practices. But, most evidence suggests that the AMA does not expect another delay.

In fact, the AMA website now states “Practice management experts caution that physicians now should begin preparing their practices for the transition to ICD-10.” The AMA has even taken the dramatic step of setting up a special two-day ICD-10 Summit for practice managers and clinicians on June 1 and 2.

We are not yet seeing an uptick of ICD-10 conversion activity among the smaller hospitals in the country — those which, historically, have been slow to tackle their ICD-10 preparations. Hopefully, with the new year here and a positive result from the first CMS end-to-end testing round, the industry as a whole will get back into gear — and quickly!

We urge you to re-energize your ICD-10 team, if you have not already done so. If you need support or more information — contact me!