Medicare Compliance & Reimbursement

CMS confirms pushback.

The long awaited word is out: You have to go live with ICD-10 Oct. 1, 2014, according to the final rule issued by the CMS in the Federal Register, scheduled to be published on Sept. 5, 2012. The rule is available online at http://federalregister.gov/a/2012-21238 and on FDsys.gov.

CMS states, "Finally, this rule changes the compliance date for the ICD-10-CM and ICD-10-PCS medical data code sets (hereinafter "code sets") from October 1, 2013 to October 1, 2014."

According to the final rule, a standard unique health plan identifier (HPID), National Provider Identifier (NPI) and the requirements to establish its implementation have also been adopted. It will include a data element that will serve as other entity identifier data (OEID).

The following dates are critical according to the transmittal:

"Effective date: These regulations are effective on November 5, 2012.

Compliance dates: Health plans with the exception of small health plans must obtain an HPID by November 5, 2014. Small health plans must obtain an HPID by November 5, 2015. Covered entities must use HPIDs in the standard transactions on or after November 7, 2016. An organization covered health care provider must comply with the implementation specifications in §162.410(b) by May 6, 2013."

Background: The U.S. Department of Health and Human Services (HHS) published a final rule in the January 23, 2004 Federal Register (69 FR 3434), which established the standard for a unique health identifier for health care providers for use in the health care system and adopted the National Provider Identifier (NPI) as that standard ("2004 NPI final rule").

What this means for you: You need to ensure that your practice/facility is ready for ICD-10 and compliant with the NPI, HPID and OEID. Unless there is a smooth transition to the updated medical data code sets and compliance with Version 5010 and ICD-10 by all covered entities, there could be a negative impact on all other industry segments and result in returned claims and provider payment delays in case of failure of any one industry segment to achieve compliance, the transmittal points out.

HIPAA benefits: "The adoption of the HPID and the OEID will increase standardization within HIPAA standard transactions and provide a platform for other regulatory and industry initiatives," the transmittal states.