HSS has 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.
HSS sites these important issues as drivers for moving forward with adoption of ICD-10-CM and ICD-10-PCS:
1. Space Limitations
Additional need for new codes for reporting new and changing medical advancements (newly identified disease entities, new technologies and devices) has exhausted the functionality of the classification system
2. Impact of Workarounds on Structural Hierarchy
Some chapters can no longer accommodate new codes, with the result that any additional codes must be assigned to other topically unrelated chapters.ഀ
3. Lack of Detail
Emerging health care technologies, new and advanced terminologies, and the need for interoperability in electronic health records (EHRs) and personal health records (PHRs), support for pay-for-performance programs (aka value-based purchasing or competitive purchasing), development of rapid interventions for emerging diseases affecting international populations, utilization review, disease management, and research─all required code specificity nto available in ICD-9-CM.
4. Mortality Reporting and Biosurveillance
138 countries have adopted ICD-10 for coding and reporting mortality data, and 99 countries have adopted ICD-10 or a clinical modification for coding and reporting morbidity data; as a global community, it is vital that our health care data represent current medical conditions and technologies using codes compatible with the international version.
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,
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.
Note: A simultaneously issued Health Insurance Reform; Modifications to the Health Insurance Portability and Accountability Act (HIPAA) Electronic Transaction Standards─Proposed Rule updates the versions of the standards for electronic transactions originally adopted in the regulations. Version 5010 of the X12 electronic data transaction standards anticipates the eventual use of ICD-10 diagnosis codes and adds a qualifier as well as the space needed to report the number of characters that would permit reporting of ICD-10 diagnosis codes on professional claims.
Versions 5010 and D.0, health plans, including small health plans, health care clearinghouses and covered health care providers, will be required to be compliant on and after April 1, 2010.
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