ICD-10 Delay: Stunning Developments and Next Steps

Just 3 weeks ago at the 2014 HIMSS Conference, CMS Administrator Marilyn Tavenner declared the ICD-10, 2014 go-live date “solid.” Then, I received my first notification last Thursday with more notices coming in last night. Now, it is expected to become federal law late by this afternoon after President Obama signs it. I am referring to H.R. 4302, the Medicare Sustainable Growth Rate Bill (aka “fix doc pay” legislation). Someone “slipped” in a few of lines about delaying the ICD-10 transition for another year. As Dan Bowman of FierceHealthIT points out: “U.S. Senators mentioned the ICD-10 portion of H.R. 4302, a grand total of zero times; not one word. Considering the measure--all seven lines--was seemingly slipped into the middle of the bill, cloak-and-dagger style, even 10 seconds devoted to ICD-10 would have been better than nothing at all.” This was a sudden, and very unexpected, development. There are some nice things about this Bill, but ICD-10 matters did not belong in this legislation.

The unknown consequences, both positive and negative, of this have yet to be determined. CMS, the State governments, facilities, payers, organizations, and others have to shift gears, and at the same time, many people, payers, and others are breathing a sigh of relief. It cuts both ways and now we just need to move forward. However, one thing does remain: The US is the last industrialized country to adopt ICD-10. ICD-11 is tentatively scheduled to be released in 2017, just two years after the new US ICD-10 deadline (October 1, 2015). Much work is to be done and for behavioral health organizations who still do not think ICD-10 applies to them, consider this a reprieve and an opportunity.

Right now, my clients are struggling to update to DSM-5. Many state governments have not made the shift in clinical requirements to DSM-5 yet even though the American Psychiatric Association has said the "transition to DSM-5 is expected to be complete" by January 1, 2014. The DSM-5 updates, not to mention the more specific ICD-10 code sets, constitutes a huge shift in organizational cultures, compliance, and willingness. Many organizations “top 20” diagnoses are heavily weighted with the NOS designation. My fear is that auditors will not care for this much when DSM-5 and ICD-10 are fully in effect. That means that clinicians, physicians, nursing staff, and others will have to change their entrenched ways of diagnosing and clinically documenting in the medical record. And, it appears that DSM-5 is fully in effect right now, which means we need to be training staff and transitioning to that code set.

I strongly recommend that you begin your DSM-5/ICD-10 transition process now. The scope of this is very large, especially testing systems and the clinical training components. Training clinicians in the dual manuals, the intricacies of the manuals, and to practice dual coding with continuous utilization review will be imperative to maintaining a strong fiscal foundation for your organization when ICD-10 goes into effect.