New Bill Calls for Dual Coding After ICD-10 Transition

A bill that would allow providers to submit claims using either ICD-9 or ICD-10 codes after the October 1, 2015 ICD-10 transition date was introduced into the US House of Representatives on Friday.

The bill, H.R. 3018, Coding Flexibility in Healthcare Act of 2015 (Code-FLEX), would create a “safe harbor period” for the transition from ICD-9 to ICD-10 by allowing dual coding for six months after the ICD-10 transition deadline, according to an article in ICD-10 Monitor. The bill was introduced by Representatives Marsha Blackburn (R-TN) and Tom E. Price (R-NC).

Payers would be required to accept claims submitted in either code set until April 1, 2016. A supporter of the bill, Robert Tennant, senior policy advisor with the Medical Group Management Association, told ICD-10 Monitor that this is “not a delay” since it would “permit those providers who are ready to start submitting [ICD-] 10 codes on October 1 to do so.”

AHIMA: Dual Coding ‘Not Practical or Feasible’

AHIMA officials have come out against dual coding, saying the practice is not practical or feasible.

“A dual coding system is not a simple solution, but is fraught with difficulties that have the potential to undermine the data infrastructure of the healthcare industry,” states an AHIMA FAQ on ICD-10. “It will confuse claims processing and negatively impact the handling of important patient clinical information and may affect patient care.

“It would require extremely complex and costly changes to major payment, clearinghouse, and provider systems. The communication of health information between providers would be compromised, adversely impacting the quality of patient care and increasing the potential for patient harm.”

The Centers for Medicare and Medicaid Services (CMS) has stated in the past that they and many commercial health plans are unable to process claims for both ICD-9 and ICD-10 codes submitted for the same dates of service, the AHIMA FAQ states.

“For more effective, safer, and better patient care, we must move forward with the use of ICD-10 codes on October 1, 2015,”said AHIMA CEO Lynne Thomas Gordon.

Yet Another ICD-10 Bill

H.R. 3018 is the latest in a slew of ICD-10 related bills and announcements that have hit the industry over the past few weeks. On Monday, the American Medical Association (AMA) and CMS announced new guidance to help ease providers into the transition from ICD-9 to ICD-10 by creating a 12-month grace period on inaccurate ICD-10 code use.

On June 26, the Senate Appropriations Committee opted not to adopt amendments aimed at slowing down full implementation of ICD-10-CM/PCS in a markup session of an appropriations bill.

And on June 4, a bill was introduced into the US House that proposed a two-year “grace period” for accepting codes submitted in ICD-10-CM/PCS. The bill, H.R. 2652, Protecting Patients and Physicians Against Coding Act of 2015, was introduced by Representative Gary Palmer (R-AL-6).

That legislation was the third ICD-10-related bill to be introduced into the House of Representatives since April. On May 12, H.R. 2247, the Increasing Clarity for Doctors by Transitioning Effectively Now Act (ICD-TEN Act) was introduced by Rep. Diane Black (R-TN-6) calling for an ICD-10 transition period. On April 30, H.R. 2126, the Cutting Costly Codes Act of 2015, was introduced by Rep. Ted Poe (R-TX-2) seeking to outright stop the replacement of ICD-9 with ICD-10.


  1. We need to move forward. All the other countries are way ahead of us. People, we have to do this to better out Heathcote in the United States.

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  2. The time is now to transition completely to ICD 10. I have coworkers who told me nightmare scenarios regarding dual coding, especially inpatient coding. The DRGs frequently don’t match. The reimbursement is usually higher for ICD 10 than it is for ICD 9. Dual coding is also more time-consuming and the representatives responsible for this just don’t understand that. Congress needs to accept that ICD 10 is here and not going away.

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  3. I couldn’t agree more with what Robin or anyone else who may come on here will say. The USA is the only country in the WORLD that still uses I-9. Everyone else, including all our allies, switched to I-10 decades ago, and some of these countries are now working on the development of ICD-11. ICD-9 is over 30 years old, and it can’t be expanded any more than it already has been. Even worse, I-9 doesn’t have the level of specificity that researchers and providers are demanding in today’s complex healthcare delivery environment. Any further delay in implementation of its replacement, I-10, will cost consumers and providers MILLIONS of dollars. It will also cause massive confusion, which in turn has the potential to open the heathcare delivery system to fraud, waste, and abuse. In short, any more delays just AREN’T WORTH IT.

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    • No country in the world is using the Icd-10 code set that we are about to begin using. The main reason for our delay in adopting Icd10 was due to the inadequacey of ICD-10 as developed by WHO for our most advanced health care industry. While ICD is much better than ICD9 for many reasons, it will still require much revision over the years.

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      • Jeffrey, your information is incorrect. Every country that uses ICD (in any form) makes their own modifications. In Canada, you have ICD-10-CA for example. The US version is ICD-10-CM (clinical modification). We also are the only country to use PCS (which was created for US use only). The reason it has taken the US so long is we are the only country in the world that ties coding to reimbursement, and THAT takes it to congressional rule making processes. That is the reason for the delay in the US. The clinical modification (with minor changes) has been in use in non-reimbursement ways for many years (example is mortality and morbidity stats) in the US. Reimbursement and congressional imput/impact is why we are so far behind.

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  4. Although it is a fact that ICD10 is here to stay, probably the dual coding, how so ever time consuming it may seem, may offer supplementary help in the transition.

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