News: IPPS Proposed Rule states new ICD-10-CM/PCS implementation as Oct. 1, 2015

The new ICD-10-CM/PCS implementation date looks to be October 1, 2015. CMS mentioned October 1, 2015, as the new date three times in the IPPS Proposed Rule, released April 30. The following day, CMS released a statement verifying its plan for an October 1, 2015, implementation.

According to the May 1 CMS statement:

On April 1, 2014, the Protecting Access to Medicare Act of 2014 (PAMA) (Pub. L. No. 113-93) was enacted, which said that the Secretary may not adopt ICD-10 prior to October 1, 2015. Accordingly, the U.S. Department of Health and Human Services expects to release an interim final rule in the near future that will include a new compliance date that would require the use of ICD-10 beginning October 1, 2015. The rule will also require HIPAA covered entities to continue to use ICD-9-CM through September 30, 2015.

The original implementation date of October 1, 2014, was delayed by the surprise inclusion in legislation in HR4302 “Protecting Access to Medicare Act of 2014” which, although it aimed to address problems with the Sustainable Growth Rate (SGR) formula for physician Medicare reimbursement, included the delay and other “add-on” amendments.

Many in the healthcare industry—including AHIMA, ACDIS, AHA, and others—quickly voiced opposition to the delay. CMS itself indicated that the delay came as a surprise having adamantly endorsed its professed 2014 implementation.

Since the Congressional vote on March 31, the mantra from many in the industry has been to “stay the course” with ICD-10-CM/PCS training and implementation efforts. During AHIMA’s ICD-10-CM/PCS Summit at the end of April, Denise Buenning, MsM, acting deputy director for CMS’ Office of E-Health Standards and Services, told the group the agency was “close” to having a new official implementation date for the industry.

Regardless of whether the date in the Proposed Rule is simply a clerical error (on p. 121 it also lists October 1, 2014 as the implementation date), a suggestion of what the new hoped-for date may be, or an actual Proposed Rule, facilities should not be distracted by date debate, says ACDIS Director Brian Murphy. “Clarifying documentation in the medical record is what CDI is about. Continuing with documentation improvement efforts in ICD-9-CM will only help when the ICD-10-CM/PCS transition does finally come,” he says.

Additional measures in the Proposed Rule focus on quality, VBP, and readmissions

CMS added new quality measures and penalties for new categories of readmitted patients, emphasizing its push to improve the quality of healthcare through payment initiatives in IPPS Proposed Rule, as well as possible change the criteria for an inpatient admission.

Hospitals will see a net increase of 0.8% in payments, according to CMS. As always, some MS-DRG weights increased, while others decreased. Facilities should review the relative-weight change tables included in the proposed rule.

Facilities still face a negative 0.8% recoupment adjustment under the Documentation and Coding Adjustment, and CMS expects to make similar adjustments in FY 2015, 2016, and 2017 in order to recover the full $11 billion mandated in the American Taxpayer Relief Act of 2012.

“I personally believe that any ‘improvement’ in a facility’s case mix index with clinical documentation and coding integrity is a truer reflection of their patient’s actual resource intensity in contrast to the ‘underdocumentation’ that occurred prior to MS-DRGs,” says James S. Kennedy, MD, CCS, CDIP, managing director of FTI Healthcare in Brentwood, Tenn. “Even so, I believe that hospitals and physicians, as well as the entire healthcare delivery system, benefits in their partnership to consistently define, diagnose, and document conditions and treatments as to deploy clinically congruent ICD-9-CM codes essential to MS-DRGs and in their preparation for ICD-10-CM’s impact as well.”

Editor’s Note: ACDIS members received additional information in a special news report released last week. Please check the ACDIS Blog for additional information related to the ICD-10-CM/PCS delay.