Proposed Delay in ICD-10 Compliance Deadline: What Does It Mean to You?

April 10, 2012


A newly proposed rule gives healthcare providers an additional year to implement the International Classification of Diseases, 10th Edition (ICD-10), diagnosis and procedure codes. On April 9, 2012, the U.S. Department of Health and Human Services proposed that organizations would need to be in compliance by Oct. 1, 2014.

What would this deadline postponement mean for your healthcare organization? How would it affect the organization’s overall timeline for implementing regulatory requirements?

Is Your Transition to ICD-10 on Track?
Oct. 1, 2014, may seem far away, but it is just around the corner. It can be challenging to juggle ICD-10 with ongoing electronic health records implementation or optimization and Meaningful Use compliance. To allow adequate time for your organization’s ICD-10 activities, Crowe Horwath LLP recommends completing the following tasks by Dec. 31, 2012:

  • Complete Meaningful Use Stage 1 attestation (eligible professionals and hospitals only).
  • Conduct an ICD-10 executive-level assessment to determine your organization’s overall risk of compliance.
  • Assign a qualified project manager to lead your ICD-10 initiative.
  • Perform an application inventory to gauge remediation efforts on technology infrastructure.
  • Conduct an ICD-10 in-depth assessment to determine the enterprisewide risk of compliance.
  • Estimate budgets for ICD-10 training, technology enhancement, and changes to clinical, revenue cycle, and operational processes.
  • Develop a strategic project plan that takes your organization from its current state to enterprisewide ICD-10 compliance.

Once these efforts are completed, there will be ample time for enterprisewide remediation before the proposed Oct. 1, 2014, deadline for compliance.

The Cost of Noncompliance
For even the smallest healthcare organization, the consequences of being unprepared for ICD-10 can be significant. For starters, payment reimbursement time may increase a minimum of 14 days for the first six months after the ICD-10 compliance deadline. In addition, noncompliant documentation and coding means inefficiencies and error rates that can prolong the reimbursement process, increasing claims processing time by as much as 25 percent.

Contact Information
For more information, please contact Mike Koehler at 630.706.2014 or mike.koehler@crowehorwath.com.

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Mike Koehler