Home Health & Hospice Week

Don’t let skepticism endanger your compliance.

Mark your calendar in red for Oct. 1, 2015. You have less than 18 months to prepare for the new ICD-10 diagnosis code set implementation date.

The Centers for Medicare & Medicaid Services quietly set a new date in the new 2015 Inpatient Prospective Payment System Proposed Rule, which cites Oct. 1, 2015 as the new ICD-10 implementation date in several different spots. “The ICD-10-CM/PCS transition is scheduled to take place on October 1, 2015,” the proposed rule states on page 648. In addition, the document refers to the 2015 date in two other instances as well.

You might be skeptical of any new compliance date CMS sets, considering the agency’s insistence that it wouldn’t move from the previous October 2014 date. But that date got postponed only because Congress enacted the change, observers point out. CMS is highly unlikely to bump the date under its own steam.

However, Congress could always be persuaded to enact another postponement. Such speculations are likely to hamper providers’ ICD-10 preparations — and endanger your compliance with the coding set when it does take effect.

Plus: Don’t expect to get a jump on using ICD-10. “The rule will also require HIPAA covered entities to continue to use ICD-9-CM through Sep-tember 30, 2015,” notes HHH Medicare Admini-strative Contractor CGS on its website.

End-to-end testing of claims with ICD-10 codes has been canceled for this July, but will be available in 2015, CGS adds.

No word yet: CMS still hasn’t decided whether it will delay OASIS-C1 implementation to October 2015 as well, or stick with the October 2014 date currently in place, a CMS source tells Eli.