AHIMA Comments on Proposed ICD-10 Rule

AHIMA has submitted official comments on the adoption and implementation of the ICD-10-CM and ICD-10-PCS classification systems. In part, AHIMA:

  • Recommends that the implementation of the two classifications and the related HIPAA transaction updates should occur over a three-year period, with the date of final compliance no later than October 1, 2012
  • Supports a single compliance date across the entire US healthcare industry and recommends that the compliance date, once designated, not be extended, which would cause confusion and add costs
  • Recommends that the ICD-9-CM, ICD-10-CM, and ICD-10-PCS code sets be frozen for one year prior to the compliance date; that is, the same set of codes would be used for the fiscal year before and after the compliance date
  • Requests clarification on how Medicare PPS programs will be immediately affected at the compliance date
  • Calls on leadership at Health and Human Services and the Centers for Medicare and Medicaid Services to ensure that the transition occurs across the industry—especially related to Medicare and Medicaid programs—and that sufficient testing takes place in advance of the deadline

AHIMA also commented on managing ICD-9 in the interim. ICD-9 will run out of codes before ICD-10 is implemented, perhaps as early as next year, and AHIMA recommends against using any unassigned ICD-9 code in any chapter for any type of procedure once the two open series of codes have been depleted.

AHIMA also commented on the proposed update to the HIPAA-related Transaction Standards, which is needed to accommodate the ICD changes and improve the transactions themselves.

AHIMA expressed its commitment to work with the healthcare industry and Health and Human Services to help ensure a smooth transition and a trained workforce.

All comments submitted to HHS are available at regulations.gov. Search on the code “CMS-0013-P” for the ICD-10-related comments and on “CMS-0009-P” for the HIPAA-related comments. HHS intends to review comments promptly, and there is some expectation that it will submit a final rule by the end of the year.

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