As expected, President Obama signed the “Protecting Access to Medicare Act of 2014.”  The law contains a one year SGR fix, a delay to the two-midnight rule, and, most surprisingly, a minimum of a one year delay in ICD-10.

The language of the law is quite specific that HHS cannot make ICD-10 the standard before October 1, 2015, but the delay raises more questions than answers for healthcare providers:

• Will the date for implementation be October 1, 2015, or later? There are advantages to CMS if the transition is scheduled at the beginning of the Medicare Fiscal Year, so probably yes.
• Will CMS scrap ICD-10 entirely for ICD-11? Extremely unlikely. Even though ICD-11 is expected in 2017, it would take several years to develop the clinical modifications and associated procedure coding standards, and then several more to implement it. That’s far longer than the government is likely to wait to reap the benefits of the transition to a more detailed code set.
• Will CMS permit organizations who are ready for ICD-10 to use it in advance of the deadline? This is far more possible, but creates a logistical nightmare for early adopters in terms of keeping coding requirements clear between ICD-9 payers and those willing to accept ICD-10.
• How will service vendors who provide training, subscriptions, and contract coding services adapt to the changing deadlines? This remains to be seen.

Hospitals can begin talking to their vendors about approaches to contract delays, but finalization of those changes and making a good strategic decision on the rest of the implications of the delay will require clarification from CMS.

Phoenix is currently working through these issues with a number of hospitals as they refocus their ICD-10 project plans.  If you would like to speak with us about your situation, contact us at info@phoenixhealth.com or on our website.