Call to Action – ICD-10 Grace Period
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As we approach the October 1, 2015 implementation date of the International Classification of Diseases, Clinical Modification, 10th Revision (ICD-10), I am writing to express my continued concern over the readiness of our healthcare system to transition to this new coding system.
While many participants in our system have invested considerable time and resources to prepare for this transition, the threat of significant disruption remains. Even some of the most enthusiastic backers of ICD-10 implementation publicly acknowledge that implementation will lead to reduced productivity and technical glitches that may severely impact health care operations across all providers and payers. Congress and the Administration should take steps to mitigate the impact that such disruptions will have on health care systems and our patients.
We have seen other HIPAA mandated changes, such as the National Provider Identifier (NPI) and the upgrade to Version 5010 transaction standards, cause disruptions. These changes, which were significantly less complex than ICD-10 transition, resulted in significant claims processing disruptions that caused physicians to go unpaid for weeks and sometimes months. Such disruptions negatively impact patients’ access to care.
ICD-10 will require coding to a much greater level of specificity than is required under the current ICD-9 system. Because proficiency with this new system will require experience that comes only by doing, we urge you to support legislative efforts that result in establishing a two-year grace period during which physicians will not be penalized for errors, mistakes and or malfunctions related to adjusting to new ICD-10 coding specifications.
I appreciate your attention to this serious matter and hope that you will work with your colleagues in Congress and the Centers for Medicaid and Medicare Services to ensure that the necessary preparations to mitigate these threats are undertaken immediately.