Comment Period Ends for HHS Proposed Rule

Comment period for the HHS proposed rule published on 4/17/12 comes to an end today. The proposal among several other things, proposes to change the compliance date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding, including the Official ICD-10-CM Guidelines for Coding and Reporting, and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD-10-PCS) for inpatient hospital procedure coding, including the Official ICD-10-PCS Guidelines for Coding and Reporting, from October 1, 2013 to October 1, 2014.

A very controversial issue, this has brought all the usual and some not so usual suspects out to comment. The groups might seem to be similar in theme but their comments are all but the same. Here are some we thought you should know about:

The College of Healthcare Information Management Executives (CHIME) – urges HHS to remain committed to ICD-10, while calling the one year delay an appropriate “middle ground” for all stakeholders.

The American Medical Association (AMA) is urging for more than a year delay.

The American Health Information Management Association (AHIMA), the organization that states it represents over 64,000 health information management professionals worldwide – argues there should be no delay.

The American Hospital Association (AHA) – supports the Centers for Medicare & Medicaid Services’ proposed one-year delay and strongly recommends that CMS move forward with both the CM and PCS coding systems at the same time.

Tennessee Medical Association – advocating Oct. 1, 2014, as the final deadline for ICD-10 compliance.

Texas Medical Association – is concerned that the eventual adoption of the ICD-10 set of diagnostic codes “will introduce great cost … without a corresponding benefit.” They are glad the federal government postponed adoption of the ICD-10 coding system until 2014 but believes it should skip ICD-10 for a more up-to-date coding system. If officials don’t do that, then they should delay ICD-10 even longer.

The Medical Group Management Association (MGMA) – suggests doing a list of things before considering adopting ICD-10. Among those items are doing a comprehensive cost benefit analysis, pilot programs, and consider additional code set approaches.