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CHIME files comment letter on ICD-10 compliance

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ANN ARBOR, MI, May 9, 2012 - The College of Healthcare Information Management Executives (CHIME) today submitted comments to Health and Human Services Secretary Kathleen Sebelius regarding a notice of proposed rulemaking to postpone the compliance date for International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10) to October 1, 2014.

In its comments, CHIME urged HHS to remain committed to ICD-10, while calling the one year delay an appropriate “middle ground” for all stakeholders.

“A longer delay would seriously disrupt ongoing efforts to convert to ICD-10,” the letter said. “And, as HHS itself recognizes, a longer delay would significantly increase the costs of converting to ICD-10. Thus, we compliment HHS for attempting to balance the interests of all stakeholders by identifying a middle ground between those who urge a longer delay, which we believe would create more problems than it would solve, and those who would prefer no change in the compliance date.”

The April notice of proposed rulemaking followed an earlier announcement by the Secretary that a delay was imminent. In response to that announcement, CHIME wrote to HHS Secretary Sebelius in February, urging HHS “to move quickly and decisively in setting a new compliance date for converting to ICD-10.” In its letter, CHIME said a prolonged delay to ICD-10 implementation, or more specifically, prolonged uncertainty about the timing and details of a delay, would create more problems than it would solve.

“We compliment HHS for the timing of this announcement and for their prompt consideration of the issue,” said Sharon Canner, CHIME’s Senior Director of Advocacy. “Many organizations have made, or are planning for, substantial investments in technology, training and education. The ICD-10 code set will also introduce a new level of data granularity for doctors and hospitals that will ultimately lead to better outcomes.”

CHIME also complimented the unified approach proposed by HHS to ensure that all providers have the same compliance date. For the conversion to ICD-10 to proceed smoothly, CHIME recommended that all segments of the provider community be in lockstep regarding conversion

timeframes. However, if HHS decides to entertain different ICD-10 compliance deadlines for different covered entities, CHIME said it would be most useful to set an earlier compliance date for health plans (payers). “[A] consistent compliance date across the provider community and an earlier date for payers would make the delay much more meaningful,” the comments said.

Finally, CHIME recommended that HHS move steadily towards its proposed compliance deadline for ICD-10 and dismiss calls to “leapfrog” from ICD-9 to ICD-11.

“Everyone in the healthcare IT world is working against numerous deadlines,” said George Hickman, executive vice president and chief information officer at N.Y.-based Albany Medical Center. “But it’s vitally important for those of us planning, budgeting and implementing these projects to know when those deadlines are coming. ICD-10 is a major undertaking, and we encourage HHS to be vigilant in monitoring industry readiness, while making clear its intentions regarding the final compliance date.”

To help HHS develop an appropriate path for making the transition to ICD-10, CHIME offered its assistance and expertise to optimize the positive effects of ICD-10 and make the transition as smooth as possible.

To read CHIME’s comment letter to HHS, click here.

About CHIME

The College of Healthcare Information Management Executives (CHIME) is an executive organization dedicated to serving chief information officers and other senior healthcare IT leaders. With more than 1,400 CIO members and over 70 healthcare IT vendors and professional services firms, CHIME provides a highly interactive, trusted environment enabling senior professional and industry leaders to collaborate; exchange best practices; address professional development needs; and advocate the effective use of information management to improve the health and healthcare in the communities they serve. For more information, please visit www.cio-chime.org.


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