HSS has FINALLY issued an NPRM (Proposed Rule) published in the Federal Register on August 22, 2008 that proposes the adoption of ICD-10 effective October 1, 2011. Should this rule be made final all covered healthcare entities- health care providers, healthcare plans, and healthcare clearinghouses who must comply with HIPAA regulations……ICD-10-CM will be the standard code set for reporting and coding diseases, injuries, impairments, other health problems and their manifestations, to replace ICD-9-CM Volumes 1 and 2.

Additionally, ICD-10-PCS would replace ICD-9-CM Volume 3, including the official coding guidelines, for the following procedures or other actions taken for diseases, injuries, and impairments on hospital inpatients reported by hospitals: prevention, diagnosis, treatment, and management.

All HIPAA covered entities would be required to use these codes when diagnoses and hospital inpatient procedures need to be coded in HIPAA transactions. Because ICD-10-PCS codes are only used for inpatient hospital procedures, the ICD-10-PCS codes would not be used in outpatient transactions.

An ICD-10-CM/PCS Coordination and Maintenance Committee would be established. This committee will follow the same procedures currently used by the ICD-9-CM Coordination and Maintenance Committee to consider new codes and revisions to existing codes.

October 1, 2011 is proposed as the compliance date for ICD-10-CM and ICD-10-PCS code sets for all covered entities. It is important to note that the compliance date must occur on October 1 in order to coincide with the effective date of annual Medicare inpatient PPS updates. Projected compliance dates for other health IT initiatives have been sequenced in a manner that will allow covered entities to concentrate their efforts on ICD-10 implementation (including the implementation of the 5010 transactions) during the relevant period. The proposed compliance date is also sufficiently far in the future to provide all sectors of the industry, including small health plans, adequate time to implement the code sets.

Upon publication of the proposed rule in the Federal Register, both the industry and CMS will/should actively initiate and/or complete planning for implementation of ICD-10.

Once the ICD-10 and Version 5010/NCPDP Version D.0 (electronic transaction standards) final rules are published, CMS estimates that both CMS and the industry will begin documenting the requirements for both ICD-10 and Version 5010 system changes, initiate and/or complete any gap analyses, and then undertake design and system changes. Version 5010 progressing first, based on the need to have this transaction standard in place prior to ICD-10 implementation to accommodate the increase in the size of the fields for the ICD-10 code sets.