ICD-10 New Compliance Date: HIPAA & HITECH Act Blog by Jonathan P. Tomes

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The U.S. Department of Health and Human Services (“DHHS”) issued a rule on August 1, 2014, finalizing October 1, 2015, as the new compliance date for health care providers, health plans, and health care clearinghouses to transition to ICD-10, the tenth revision of the International Classification of Diseases. This deadline allows providers, insurance companies and others in the health care industry time to ramp up their operations to ensure that their systems and business processes are ready to go on October 1, 2015. Good luck.

ICD-10 is the 10th revision of the International Statistical Classification of Diseases and Related Health Problems (“ICD”), a medical classification list by the World Health Organization (“WHO”). It contains codes for diseases, signs and symptoms, abnormal findings, complaints, social circumstances, and external causes of injuries and diseases.

The code set allows more than 14,400 different codes and permits the tracking of many new diagnoses. The codes can be expanded to more than 16,000 codes by using optional sub-classifications.

Compliance will not be easy because no crosswalk exists between the current ICD-9 and the new ICD-10 because ICD-10 requires more information to arrive at a code. Even though the deadline for ICD-10 has been pushed back repeatedly, the Centers for Medicare and Medicaid Services (“CMS”) has recommended that medical practices take several years to prepare for implementation of the new code set. Not only must new software be installed and tested, but also medical practices must provide training for physicians, staff members, and administrators. They will also need to develop new practice policies and guidelines and to update paperwork and forms. This task will not be an easy one to accomplish by October 1, 2015, unless you have already been working on it.

For a discussion of the transition from ICD-9 to ICD-10, including ICD-10-CM (clinical modification), which contains many more codes than the base ICD-10, see Chapter 6, “Requirements for Data Sets,” in the forthcoming 6th edition of my book The Compliance Guide to HIPAA and the DHHS Regulations. I am grateful to Charles A. Penoi, our meaningful use guru, for his help with this chapter. The 6th edition of the accompanying HIPAA Documents Resource Center CD is already available, and the 6th edition of the book is in the final stages of editing and indexing now and should be available within several weeks. To order now and receive a 20% prepublication discount, call our marketing director, Patrick R. Head II, toll-free at 855-341-8783 or email him at patrick@veteranspress.com, and mention this blog post.

While you are talking with Patrick, ask him about our upcoming two-day Hands-on HIPAA Workshop aboard the Queen Mary anchored in Long Beach, California, October 16-17, 2014.

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