ICD-10 – A New Sheriff in Town – Penalties as well as Benefits

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ICD-10 – A New Sheriff in Town – Penalties as well as Benefits

Many white papers and blogs focus on benefits of ICD-10, but would be remiss if we didn’t also point out the punitive measures.  Health plans must file certification statements that they are in compliance with standards and operating rules by December 2013 including documentation, and provide proof of compliance.   In addition payers will have to provide documentation of proof of end to end to testing with providers.

These Sarbanes-Oxley like measures certainly should get your executive team’s attention if the benefits do not.


The laws have already been enacted. Organizations who do not comply may be subject to a fine of $1.00 per covered life per day if they do not meet the certification requirements.  These penalties double if inaccurate or incomplete information has been provided in the compliance documentation.   This means that a relatively small health plan with 100,000 members could be subject to a $2 million fine, per year.

See ICD-10 Assessments here.

By | 2017-05-04T04:07:02+00:00 June 21st, 2010|ARRA, CORE Operating Rules, health care reform, ICD-10|0 Comments

About the Author:

Michael is Managing Partner & CEO of No World Borders, a leading health care management and IT consulting firm. He leads a team that provides Cybersecurity best practices for healthcare clients, ICD-10 Consulting, Meaningful Use of Electronic Health Records. He advises legal teams as an expert witness in HIPAA Privacy and Security, medical coding and billing and usual and customary cost of care, the Affordable Care Act and benefits enrollment, white collar crime, False Claims Act, Anti-Kickback, Stark Law, Insurance Fraud, payor-provider disputes, and consults to venture capital and private equity firms on mHealth, Cloud Computing in Healthcare, and Software as a Service. He advises self-insured employers on cost of care and regulations. Arrigo was recently retained by the U.S. Department of Justice (DOJ) regarding a significant false claims act investigation. He has provided opinions on over $1 billion in health care claims and due diligence on over $4 billion in healthcare mergers and acquisitions. Education: UC Irvine - Economics and Computer Science, University of Southern California - Business, Stanford Medical School - Biomedical Informatics, Harvard Law School - Bioethics.
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