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HIPAA Electronic Code Set Transition Delayed to October 1, 2015
Practical Law Legal Update 9-576-8548 (Approx. 3 pages)
HIPAA Electronic Code Set Transition Delayed to October 1, 2015
by Practical Law Employee Benefits & Executive Compensation
| Published on 04 Aug 2014 • USA (National/Federal) |
Reflecting legislation enacted earlier this year, Department of Health and Human Services (HHS) final regulations have established October 1, 2015 as the new compliance date for the health care industry's transition to the International Classification of Diseases codes, 10th Revision (ICD-10).
On July 31, 2014, the Department of Health and Human Services (HHS) issued final regulations that delay the compliance date for the International Classification of Diseases, 10th Revision (ICD-10), from October 1, 2014 to October 1, 2015 (79 Fed. Reg. 45128). As background, HIPAA covered entities (including group health plans) must transmit certain information in electronic transactions using standardized medical data code sets (for example, coding of medical diagnoses). The transaction standards and code sets are intended to standardize the exchange of electronic data by reducing the use of multiple formats (see Practice Note, HIPAA Electronic Transactions under the ACA). The ICD-10 code sets, in particular, will replace use of the existing ICD-9 code sets to offer greater coding functionality and related improvements.
The transition to ICD-10 has been postponed before. In 2012, the ICD-10 compliance date was delayed from October 1, 2013 to October 1, 2014, due to concerns over industry readiness (see Legal Update, HHS Proposed Regulations Address Unique Health Plan Identifiers and Delay Code Sets Compliance Date).
Under the Protecting Access to Medicare Act of 2014 (PAMA), enacted this past April, HHS could not adopt ICD-10 earlier than October 1, 2015 (P.L. 113-93). Consistent with PAMA, the final regulations establish October 1, 2015 as the new ICD-10 compliance date. The final rules also require use of the ICD-9 code sets through September 30, 2015.
ICD-10 Advantages
A one year delay was the shortest delay permitted under PAMA. According to HHS, the October 1, 2015 compliance date was chosen because a longer delay would impede industry ICD-10 compliance efforts already underway. In previous guidance (73 Fed. Reg. 49796), the government noted various limits of the ICD-9 code sets, including:
- Space limitations for additional codes, which has resulted in new codes being added to inappropriate sections (for example, codes for heart procedures being placed in a chapter for eyes).
- Lack of coding detail. For example, the ICD-9 codes have only one code for a wrist fracture, making it difficult to identify whether a second fracture is a repeat of the same wrist or a fracture of the other wrist.
The government expects use of ICD-10 to:
- Provide greater specificity in diagnosis-related groups.
- Offer greater accuracy in reimbursements for medical services.
- Improve tracking of illnesses, quality measurement and reporting capabilities.
Practical Impact
Although the one-year delay of ICD-10 implementation is the minimum allowed under PAMA, the new compliance date will impact health plans that may have developed budgets, allotted resources and chosen contractors before PAMA and the final regulations, in anticipation of the October 2014 compliance date. Moreover, IT systems preparations and staff training schedules relating to ICD-10 may need to be reconsidered in light of the October 1, 2015 compliance date.