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No Fines for Lack of ICD-10 Compliance, Only Lost Revenue

Practices are well aware of the pending changes stemming from the transition to the new ICD-10 coding set that will occur on October 1, 2013, and many already are in the midst of making sure that they are fully prepared for this shift. Some steps that practices are taking right now include: developing committees to assess what software and IT upgrades need to be made; finalizing internal staff training plans; and creating implementation plans to ensure readiness by all staff.

Although these steps are exactly what practices should be doing to prepare for ICD-10, many people are still wondering if the compliance deadline will be extended—and what penalties they will face if their practices are not prepared when that deadline rolls around.

First, I am confident in saying that ICD-10 has a hard cut-over date of October 1, 2013. The Centers for Medicare and Medicaid Services (CMS) feels like it already has granted practices a two-year “extension” of sorts by pushing back its originally proposed 2011 implementation date.

In addition, CMS has articulated its commitment to the October 1, 2013 implementation date: Any request for payments for services provided on or after October 1, 2013, must be submitted using ICD-10 codes. However any claim for services provided prior to October 1, 2013, must use ICD-9 codes—further emphasizing CMS’ desire to have the current implementation date hold.

This steadfast date is unlike many healthcare industry changes in the past, where implementation dates were extended or a grace period was provided. So, practices wonder what will happen if they are not ready for the conversion in two and a half years. Will the government levy fines against practices?

Although unprepared practices will feel the repercussions, it will not come in the way of fines. Instead, the penalty will be come in the form of rejected or denied claims, and practices will not get paid. If that is not enough incentive to prepare for the transition, I am not sure what would be.