#ICD10 #NoDelay Trending on Twitter Today, Testing is Issue Not the Delay

ICD-10, the International Classification of Diseases version 10 from the World Health Organization (WHO) is supposed to go into effect in the United States on October 1, 2014 2015.  Today on Twitter, proponents of ICD-10 asked the U.S. Senate not to delay ICD-10 as part of H.R. 4302.  H.R. 4301 is designed primarily to re-adjust  the Sustainable Growth Rate (SGR) for Medicare payments. Section 212,  states that the Department of Health and Human Services (HHS) cannot implement ICD-10 October 1, 2015 or perhaps later.

The final AYE was cast on Monday March 31st at approximately 6:45pm to delay ICD-10 as part of H.R. 4301.

History Repeats Itself

Healthcare.gov, the U.S. Health Insurance Exchange (HIX) went live October 1, 2013 with no real-world testing. Like Healthcare.gov, ICD-10 is going live with much larger financial impact and  limited testing by 500 health care providers who submit claims to Medicaid.  This testing is currently scheduled for July, 2014 and was only agreed to by CMS after pressure from several sources.

Test ICD-10, Instead of Delaying it Entirely

Unfortunately keeping ICD-10 on schedule or delaying it were probably both bad choices.  The reason is that there has been almost no testing of ICD-10 despite its significant impact on the $3 trillion U.S. health care economy.  A better strategy would be to keep October 1, 2014 as a deadline and enforce it for testing, much as health care providers must be tested to prove they use electronic health records for Meaningful Use stimulus funds.  Exemptions from Meaningful use dates are also provided for.  Neither testing or exemptions, even for hardships, are part of the ICD-10 mandate.  ICD-10 CM (the U.S. version of ICD-10 diagnosis codes) was not legislated with the same thoroughness of stimulus funds, exemptions and rigorous testing as Meaningful Use of Electronic Health Records.  ICD-10 has been delayed before and most physicians didn’t use the extra time to prepare, they just put it off.

Now we’ll have to see if the industry uses the extra time to implement ICD-10 wisely.  If this delay is like the last, then history will repeat itself.

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Michael F. Arrigo

Michael is Managing Partner & CEO of No World Borders, a leading healthcare management and IT consulting firm. He serves as an expert witness in Federal and State Court and was recently ruled as an expert by a 9th Circuit Federal Judge. He serves as a patent expert witness on intellectual property disputes, both as a Technical Expert and a Damages expert. His vision for the firm is to continue acquisition of skills and technology that support the intersection of clinical data and administrative health data where the eligibility for medically necessary care is determined. He leads a team that provides litigation consulting as well as advisory regarding medical coding, medical billing, medical bill review and HIPAA Privacy and Security best practices for healthcare clients, 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, physician compensation, Insurance bad faith, payor-provider disputes, ERISA plan-third-party administrator disputes, third-party liability, and the Medicare Secondary Payer Act (MSPA) MMSEA Section 111 reporting. He uses these skills in disputes regarding the valuation of pharmaceuticals and drug costs and in the review and audit of pain management and opioid prescribers under state Standards and the Controlled Substances Act. He consults to venture capital and private equity firms on mHealth, Cloud Computing in Healthcare, and Software as a Service. He advises ERISA 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 $8 billion in healthcare mergers and acquisitions. Education: UC Irvine - Economics and Computer Science, University of Southern California - Business, studies at Stanford Medical School - Biomedical Informatics, studies at Harvard Medical School - Bioethics. Trained in over 10 medical specialties in medical billing and coding. Trained by U.S. Patent and Trademark Office (USPTO) and PTAB Judges on patent statutes, rules and case law (as a non-attorney to better advise clients on Technical and Damages aspects of patent construction and claims). Mr. Arrigo has been interviewed quoted in the Wall Street Journal, New York Times, and National Public Radio, Fortune, KNX 1070 Radio, Kaiser Health News, NBC Television News, The Capitol Forum and other media outlets. See https://www.noworldborders.com/news/ and https://www.noworldborders.com/clients/ for more about the company.

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