Freezing the code sets will allow organizations to focus on the system change without managing code updates at the same time. The implementation deadline for ICD-10-CM/PCS is October 1, 2013.

Under the proposal, the last regular update of ICD-9-CM and ICD-10-CM/PCS prior to ICD-10 implementation would occur October 1, 2011.

Limited updates to incorporate new diseases and new technology would be permitted on October 1, 2012, and October 1, 2013.

Regular updates of ICD-10-CM/PCS would resume in 2014.

The proposal is similar to recommendations AHIMA published last November, although AHIMA recommended that only urgent updates be considered in 2012 and 2013.

CMS and CDC are soliciting comments on the code set freeze proposal. Comments may be e-mailed to Pat Brooks at CMS and Donna Pickett at CDC. The proposal may be published in the IPPS rule this spring, although that was not certain at the time of the meeting. A final decision is expect no later than this summer.

According to the practice brief, “A single one-size fits all map might seem like a reasonable solution; however, such a map would mean the code sets were so similar that there would be no point in transitioning to ICD-10-CM/PCS. The correlation of specificity and meaning between the two code sets is not that simple.”

Appendix A, “Examples of Complexity in Applied Mappings,” outlines examples of complexity in applied mappings, which illustrate why a one-size-fits-all map is not possible.

Appendix B, “Glossary of Terms,”  outlines  definitions for the terms used in the brief.

Freezing both the current ICD-9-CM and the new ICD-10-CM/PCS code sets will save organizations further cost and complexity by enabling them to focus on the system change without simultaneously managing code updates. The Centers for Medicare and Medicaid Services has been receiving recommendations on whether to freeze the code sets and, if so, for how long.

In a recently released statement, AHIMA recommends that:

• The final ICD-9-CM update should be FY 2012 (beginning October 2011, in conjunction with the federal government’s fiscal year).
• No updates should be made to ICD-10-CM/PCS for FY 2013 or FY 2014 (i.e., beginning October 2012).
• Updates to ICD-10-CM/PCS should resume in FY 2015 (October 2014).

Freezing code sets presents its own challenges, given that the practice of medicine will keep evolving. AHIMA recommends that exceptions should be allowed for urgently needed codes. Organizations requesting updates would be required to make a “clear and convincing” case to the Coordination and Maintenance Committee as to why the codes can’t wait for the next regularly scheduled update (such as the emergence of a new disease).

AHIMA recommends that the Coordination and Maintenance Committee, which maintains the code sets in the US, should continue to meet during the freeze in order to consider code proposals and avoid a backlog in 2014. “Working draft addenda” could keep the industry appraised of code changes slated to go into effect for FY 2015.

In addition, AHIMA recommends that flexibility be retained during the freeze to correct errors identified in the ICD-10-CM/PCS code sets, such as incorrect index entries or incorrect code references in instructional notes.

AHIMA offers ICD-10 information and resources at www.ahima.org/icd10.

• Sample project communication plan
• Sample project plan
• Sample project progress report
• Sample issues log

The online version also includes a list of communication aids that organizations may use in the transition to ICD-10-CM/PCS and a contact form for the major stakeholders leading the ICD-10-CM/PCS implementation.

As the practice brief notes, planning for the transition to ICD-10-CM/PCS is a multifaceted effort. Defining the organization’s data management plan will facilitate a smooth transition to ICD-10-CM/PCS and optimize its greater specificity.

The conversion project offered an early test of the General Equivalence Mappings and provides organizations with a process for converting their own applications to ICD-10-CM/PCS.

Rhonda Butler and Janice Bonazelli, senior clinical analysts at 3M Health Information Systems, offer an overview of the conversion in this early look into the upcoming November/December issue of the Journal.

The upgrade to the HIPAA transaction 5010 standard was announced in tandem with the January 2009 final rule mandating the upgrade to ICD-10-CM and -PCS. The 5010 standard is necessary to support ICD-10.

According to a timeline published in the final rule, by the end of 2010 covered entities should have completed internal testing and can send and receive compliant transactions (“level 1″ testing). In January 2011 they begin testing with trading partners and move into production (level 2). The compliance date for all covered entities is January 2012, one year in advance of the ICD-10 deadline.

Read more in the current issue of AHIMA ICD-TEN newsletter.

The April practice brief “Transitioning to ICD-10-CM/PCS—An Academic Timeline” outlines how and when HIM academic programs should begin integrating ICD-10-CM/PCS education into their curriculum. The article lays out the academic transition into three phases: preparation, hybrid, and full implementation. The countdown to integrating ICD-10-CM/PCS begins on August 1, 2010, when educators should start expanding curriculum content on courses affected by ICD-10-CM/PCS changes.

By August 1, 2012, certificate programs (one year or less) should have completely integrated ICD-10-CM/PCS in all coding courses, and associate and baccalaureate programs should have completely integrated ICD-10-CM/PCS in second-year coding courses.

The article includes a readiness checklist to help educators ensure their academic institutions are ready for the move. It also outlines training opportunities for the current HIM work force staff.

“The key to a graceful evolution of all curriculum throughout the ICD-10-CM/PCS implementation is early planning for curriculum revisions, creative use of teaching tools, and adequate faculty preparation,” the authors write.

There won’t be a delay on the ICD-10 final rules, according to the Centers for Medicare and Medicaid Services. The final rule for implementing ICD-10-CM and ICD-10-PCS will go into effect March 17.

The policies in the final rule are considered to be officially adopted on that date. The regulations for the HIPAA electronic transaction standards—published the same day in a separate rule—will go into effect at the same time. The HIPAA transactions must be updated to accommodate the use of the ICD-10-CM and ICD-10-PCS code sets. 

Before becoming official, the rules had been subject to a regulatory review by the new presidential administration, as well as a 60-day hold for Congressional review required by HIPAA. The final rules were published January 16, 2009.

ICD-10-CM/PCS must be implemented by October 1, 2013; the HIPAA electronic transaction standards must be operational by January 2012 and January 2013.

For more on the preparation for the ICD-10 transition, visit AHIMA’s ICD-10 Web site for analysis, tools, training, education, resources, and information.

Each issue contains news, practical coding information, the steps for implementation, educational resources, and more. The newsletter comes out monthly.

AHIMA also offers a wide range of ICD-10 information on its Web site.

The final rule was published January 16. It designates ICD-10-CM and ICD-10-PCS as medical data code sets under HIPAA, replacing the 30-year-old ICD-9-CM set. There is a single compliance date of October 1, 2013.

In the final rule, the Department of Health and Human Services states that the greater detail and granularity of ICD-10-CM/PCS will enhance the ability to measure quality outcomes and provide more precision for value-based purchased initiatives such as the hospital-acquired condition payment policy.

As the US moves toward an electronic healthcare system and increasingly uses codes for quality purposes, there is a need to capture more precise information, and the new code sets will greatly support these efforts.

The transition to ICD-10-CM (diagnoses) will affect all components of the healthcare industry.

Adoption of ICD-10- PCS will only affect those components of the industry that currently use ICD -9-CM volume 3—inpatient procedures.

HHS anticipates the estimated impact of ICD-10-CM/PCS transition costs on providers, suppliers, payers, and software and system design firms is $1,878.68 million. It projects the benefits at $4,539.63 million over 15 years.

Other regulation analysis and official comment are also available from AHIMA’s Advocacy and Public Policy Center.