ICD-10 Implementation Delayed



On August 4, 2014, the Centers for Medicare & Medicaid Services (CMS) published a final rule implementing section 212 of the Protecting Access to Medicare Act of 2014 by changing the compliance date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) from October 1, 2014 to October 1, 2015. The final rule also requires the continued use of ICD-9-CM through September 30, 2015.

On June 4, 2014, the Centers for Medicare & Medicaid Services (CMS) held a National Provider Call discussing the implementation of ICD-10 and the postponement of compliance until 2015. 

Click here to download the PowerPoint and listen to the recorded call.

The Protecting Access to Medicare Act of 2014 was signed by President Obama on April 1, 2014. As a part of the bill, ICD-10 implementation was delayed until at least October 1, 2015. CMS  is responsible for the implementation of ICD-10 and is reviewing the implications of the bill. CMS has not released a revised implementation plan or schedule.

As of April 16, 2014, the CMS website included the following note about the delay of ICD-10:

With enactment of the Protecting Access to Medicare Act of 2014, CMS is examining the implications of the ICD-10 provision and will provide guidance to providers and stakeholders soon.  This provision in the statute reads as follows:  ‘The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD-10 code sets as the standard for codes sets under section 1173 (c) of the Social Security Act (42 U.S.C. 1320d-2 (c)) and section 162.1002 of title 45, Code of Federal Regulations.’

Medicare Administrative Contractors (MACs) must wait for instructions from CMS, so they may have to wait to notify providers about how they will handle the delay of ICD-10.

See below for information related to the original implementation date and links to the official CMS site.  Note that most CMS documents currently include October 1, 2014 as the implementation date.

AOTA will continue to monitor the information from CMS and will update our site as more information becomes available.


ICD-10 Transition Set for October 1, 2014

The transition date from ICD-9 to ICD-10 coding across all health care settings is October 1, 2014, as announced in a final rule on ICD-10 compliance issued by the Centers for Medicare & Medicaid Services (CMS) (77 Fed. Reg. 54664 [September 5, 2012]). On this date, ICD-9 code sets used to report medical diagnoses and inpatient procedures will be replaced by ICD-10 code sets. The transition will require business and systems changes throughout the health care industry, as it applies to all providers and settings subject to the Health Insurance Portability and Accountability Act (HIPAA), not just those who submit Medicare or Medicaid claims.  Although there have been previous delays, CMS advises that the compliance dates are now firm with no grace period for implementation, and are not subject to change.  If providers are not ready or do not comply, Medicare will not process or pay their claims.  Preparing now can help avoid potential reimbursement issues later.

ICD-10-CM diagnosis codes will apply to all providers in every health care setting.  You must begin using the ICD-10-CM codes to report diagnoses from all ambulatory and physician services on claims with dates of service on or after October 1, 2014, and for all diagnoses on claims for inpatient settings with dates of discharge that occur on or after October 1, 2014.

ICD-10-PCS procedure codes will be used only in inpatient hospital settings. You must begin using the ICD-10-PCS codes for all hospital claims for inpatient procedures on claims with dates of discharge that occur on or after October 1, 2014.

The transition does not affect coding for outpatient procedures and physician services (including occupational therapy services); there will be no impact on Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes.  You should continue to use these codes for outpatient therapy services.  (Physician claims for services provided to inpatient patients will also continue to report CPT and HCPCS codes.)

The differences between the ICD-10 code sets and the ICD-9 code sets are primarily in the overall number of codes, their organization and structure, code composition, and level of detail.  There are approximately 70,000 ICD-10-CM codes compared to approximately 14,000 ICD-9-CM diagnosis codes, and approximately 70,000 ICD-10-PCS codes compared to approximately 4,000 ICD-9-CM procedure codes.  In addition, ICD-10 codes are longer and use more alpha characters, which enable them to provide greater clinical detail and specificity in describing diagnoses and procedures.  Also, terminology and disease classification have been updated to be consistent with current clinical practice. 

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