#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 Arrigo brings four decades of experience in the software, financial services, and healthcare industries. In 2000, Mr. Arrigo founded No World Borders, a healthcare data, regulations, and economics firm with clients in the pharmaceutical, medical device, hospital, surgical center, physician group, diagnostic imaging, genetic testing, health IT, and health insurance markets. His expertise spans the federal health programs Medicare and Medicaid and private insurance. He advises Medicare Advantage Organizations who provide health insurance under Part C of the Medicare Act. Mr. Arrigo serves as an expert witness regarding medical coding and medical billing, fraud damages, as well as electronic health record software for the U.S. Department of Justice. He has valued well over $1 billion in medical billings in personal injury liens, medical malpractice, insurance fraud cases. The U.S. Court of Appeals considered Mr. Arrigo's opinion regarding loss amounts, vacating, and remanding sentencing in a fraud case. Mr. Arrigo provides expertise in the Medicare Secondary Payer Act, Medicare LCDs, anti-trust litigation, medical intellectual property and trade secrets, HIPAA privacy, health care electronic claim data Standards, physician compensation, Anti-Kickback Statute, Stark law, the Affordable Care Act, False Claims Act, and the ARRA HITECH Act. Arrigo advises investors on merger and acquisition (M&A) diligence in the healthcare industry on transactions cumulatively valued at over $1 billion. Mr. Arrigo spent over ten years in Silicon Valley software firms in roles from Product Manager to CEO. He was product manager for a leading-edge database technology joint venture that became commercialized as Microsoft SQL Server, Vice President of Marketing for a software company when it grew from under $2 million in revenue to a $50 million acquisition by a company now merged into Cincom Systems, hired by private equity investors to serve as Vice President of Marketing for a secure email software company until its acquisition and multi $million investor exit by a company now merged into Axway Software SA (Euronext: AXW.PA), and CEO of one of the first cloud-based billing software companies, licensing its technology to Citrix Systems (NASDAQ: CTXS). Later, before entering the healthcare industry, he joined Fortune 500 company Fidelity National Financial (NYSE: FNF) as a Vice President, overseeing eCommerce solutions for the mortgage banking industry. While serving as a Vice President at Fortune 500 company First American Financial (NYSE: FAF), he oversaw eCommerce and regulatory compliance technology initiatives for top ten mortgage banks and led the Sarbanes Oxley Act Section 302 internal controls IT audit for the company, supporting Section 404 of the Sarbanes Oxley Act. Mr. Arrigo earned his Bachelor of Science in Business Administration from the University of Southern California. Before that, he studied computer science, statistics, and economics at the University of California, Irvine. His post-graduate studies include biomedical ethics at Harvard Medical School, biomedical informatics at Stanford Medical School, blockchain and crypto economics at the Massachusetts Institute of Technology, and training as a Certified Professional Medical Auditor (CPMA). Mr. Arrigo is qualified to serve as a director due to his experience in healthcare data, regulations, and economics, his leadership roles in software and financial services public companies, and his healthcare M&A diligence and public company regulatory experience. Mr. Arrigo is quoted in The Wall Street Journal, Fortune Magazine, Kaiser Health News, Consumer Affairs, National Public Radio (NPR), NBC News Houston, USA Today / Milwaukee Journal Sentinel, Medical Economics, Capitol ForumThe Daily Beast, the Lund Report, Inside Higher Ed, New England Psychologist, and other press and media outlets. He authored a peer-reviewed article regarding clinical documentation quality to support accurate medical coding, billing, and good patient care, published by Healthcare Financial Management Association (HFMA) and is published in Healthcare IT News.

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