AHIMA – CHIME Submit Comments On Proposed Rule For ICD-10 Delay

Posted on by Frank J. Rosello

On  April 24, 2012 the American Health Information Management Association (AHIMA) filed a comment letterwith the Department of Health and Human Services Secretary Kathleen Sebelius and CMS Acting Administrator Marilyn Tavenner in response to a section of a proposed rule that addresses “Change to the Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets.”

The overall message from AHIMA remains clear and consistent – Delaying the ICD-10 compliance deadline is not a good idea.

In its letter, AHIMA continues to recommend there be no delay in the ICD-10 compliance deadline. Since a delay is likely, AHIMA leaders said the association will continue to work with HHS and the healthcare industry to ensure the delay is as short as possible, preferably not more than one year.

AHIMA specifically states in their letter:

“AHIMA realizes that by taking steps to consider a delay in the compliance date for ICD-10-CM/PCS the Department and CMS have, in fact, created a delay, rewarding those HIPAA-covered entities that failed to begin to implement the 2009 regulations and causing some in the industry to divert resources to other projects. Therefore, if a delay is inevitable at this point, AHIMA urges that such a delay be limited to the one year stated in the proposed rule to limit financial and information losses, and HHS should make certain that all covered entities understand that:

(A) HHS and CMS fully intend to implement and use the ICD-10-CM/PCS codes sets effective October 1, 2014.


(B) The October 1, 2014 compliance date will not be extended and those that fail to comply will be penalized for their inability to use the new code set.”

AHIMA continues its position by stating that the classification system as more than a claims and billing mechanisms. They are critical to the care and diagnosis information that can be synthesized and used for communicating issues of severity, quality and provide better healthcare for the individual patient and the community. For instance, AHIMA noted, the ICD-10 codes significantly expand the ability to document and detail incidences of domestic violence. As a result, health officials can enhance detection and treatment and develop more proactive steps to prevent domestic violence.

And yesterday, the College of Healthcare Information Management Executives (CHIME)  submitted their comments on ICD-10 proposed rulemaking to HHS Secretary Kathleen Sebelius. CHIME urged HHS to remain committed to ICD-10, while calling the one-year delay an appropriate “middle ground” for all stakeholders.

CHIME specifically states in their letter:

“A longer delay would seriously disrupt ongoing efforts to convert to ICD-10. 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.”

Also CHIME recommended that HHS move steadily towards its proposed compliance deadline for ICD-10 and dismiss the idea of jumping from ICD-9 to ICD-11.

So it appears that HHS will end up delaying the ICD-10 compliance deadline by one year as both organizations seem to view this as a logical compromise to the ongoing debate fueled by passion and resolve.  Regardless of what the delay will be in final rule, the conversion of the ICD-10 code set will introduce the data granularity for physicians and hospitals that will eventuality lead to better patient outcomes.

Click here for the AHIMA comment letter.

Click here for the CHIME comment letter.

Frank J. Rosello

is CEO & Co-Founder of Environmental Intelligence LLC.

Environmental Intelligence, LLC, is a complete, full-service healthcare IT solution provider. With a team having more than 10 years of proven clinical expertise in delivering end-to-end health IT solutions, Environmental Intelligence provides medical practices and facilities onsite expert IT consulting, installation, and implementation that is focused on physicians, their patients, and the quality of their care.

Contact us to learn more about our Physician Focused – Patient Driven® approach to Health IT.


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