HHS has already responded once to industry input and has delayed the compliance date two years in their Notice of Proposed Rulemaking (NPRM). The ruling states that all Health Insurance Portability and Accountability Act (HIPAA) covered entities must begin using the new code sets on October 1, 2013.
The new code sets are now in two segments. ICD-10-CM increases diagnosis codes from 13,000 to 68,000 codes.The accompanying ICD-10-PCS code set includes facility procedure codes and increases the total content from 11,000 to 87,000 codes.
These two expanded code sets together will enable far more effective data for the classification of morbidity and mortality data while enabling accurate claims management and reimbursement by the insurance industry.They will advance effective disease management programs and track outcomes of care to ensure quality.
All entities that are covered by the Health Insurance Portability and Accountability Act (HIPAA) must use ICD-10 codes on all HIPAA transactions. ICD-10-CM codes (diagnoses) will replace the ICD-9-CM codes for all medical diagnosis coding (inpatient and outpatient). ICD-10-PCS codes (procedures) will replace the ICD-9-CM, Volume 3, procedure codes for inpatient procedure coding.
Because of the additional granularity in ICD-10, there is not a one-to-one correspondence between all ICD-9 and ICD-10 codes. In order to select the proper ICD-10 code to replace an existing ICD-9 code, one must understand the patient or administrative context. Healthcareorganizations need the right people and processes to select new ICD-10 codes, and they cannot rely solely on automated conversions from software products or intermediaries such as clearinghouses. CMS has created tools to help with the transition:
To receive proper payment from payers, providers must begin using ICD-10 diagnosis codes for dates of service on or after October 1, 2013 and ICD-10 procedure codes for dates of discharge on or after October 1, 2013. There will not be a transition period.
All systems accepting or reporting diagnostic and procedure codes will require modification and the ability to run dual nomenclature solutions. Significant testing, cross-walk analysis, report development and data aggregation across time periods will be essential to prepare for the ICD-10 transition.
While the date 2013 implies plenty of time for planning and implementing ICD-10, the impact of the change will be bigger than most organizations expect. For instance, the payer community will want to test systems with their providers up to a year before the compliance date. To be ready, organizations must successfully meet mutually agreed upon intermediate dates.
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