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Note from Hugh

Medicare Weekly Update, August 19, 2008

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Last week was a relatively light week on the regulatory front with one significant exception. As reported below, last week CMS issued a proposed rule on the replacement of ICD-9-CM with ICD-10-CM (diagnosis codes) and ICD-10-PCS (procedure codes) effective October 1, 2011. Over the years, we have had numerous false starts on the implementation of ICD-10. So, it remains to be seen whether the proposed rule will really be finalized and, if so, whether the implementation date will remain October 1, 2011.

If this really is the beginning of the implementation process of ICD-10, hospitals should not underestimate the operational implications. ICD-10 is much more that an enhancement of ICD-9-CM. Rather, ICD-10-CM and ICD-10-PCS are completely different coding systems from ICD-9-CM.  Computer systems will need significant reprogramming and hospital staff will need extensive retraining. Many people remember the operational challenges presented by the so-called “Y2K” transition. In my view, Y2K was a “walk in the park” compared to the challenges that will be presented by the implementation of ICD-10. We should all review the proposed rule carefully, submit comments as appropriate, and keep a close eye on this process.

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