By Jennifer Bresnick 

ICD-10 implementation opponents are nowhere near ready to give up the fight as the calendar moves relentlessly towards October 1, 2015.  Despite the fact that the ICD-10 compliance date is less than 100 days away, healthcare stakeholders continue to advocate for major changes to the implementation process, pinning their hopes on a two-year “grace period” that they believe would ease the burden of transition.

The American Medical Association (AMA) has been leading the campaign to institute a mandatory timeframe during which claims could not be denied due to inaccurate or unspecific ICD-10 codes.  Backed by legislation introduced into Congress, the grace period concept has also gained favor with a number of state medical societies. 

Four major groups, including the California Medical Association, Florida Medical Association, Medical Society of the State of New York, and Texas Medical Association, recently sent a plaintive letter to Acting CMS Administrator Andy Slavitt urging the federal agency to put the safe harbor proposal into practice.

“For all of these physicians in all of these settings, the Oct. 1 mandatory implementation of the ICD-10-CM coding system is a looming disaster,” stated the associations, which together represent approximately 125,000 clinical providers.

“The results of the recent end-to-end tests give us little confidence that the nation’s physicians, electronic health records, claims clearinghouses, commercial insurance companies, and government agencies will be ready when we ‘throw the switch’ to ICD-10.”

While the medical societies voice their displeasure with the 88 percent claims acceptance rate from Medicare’s latest end-to-end testing week, CMS views the figure in a much more positive light.  Only two percent of the claims submitted during the process were rejected due to an invalid ICD-10 diagnosis or procedure code, CMS said, representing a higher success rate than previous attempts even though significantly more claims were submitted during the latest round.

Still, the AMA has pounced on the imperfect end-to-end testing numbers as evidence that enormous revenue cycle disruptions are imminent for healthcare providers across the nation. “The likelihood that Medicare will reject nearly one in five of the millions of claims that go through our complex health care system each day represents an intolerable and unnecessary disruption to physician practices,” said AMA’s immediate past president Robert M. Wah, MD in a March statement.

“Robust contingency plans must be ready on day one of the ICD-10 switchover to save precious health care dollars and reduce unnecessary administrative tasks that take valuable time and resources away from patient care,” he added.

The four professional societies agree that productivity will be the first casualty of ICD-10 implementation, followed quickly by unsustainable financial impacts.  “Even those practices that are most prepared for this transition tell us they worry about the confusion and reduced productivity they expect to accompany ICD-10,” they write. “The quite realistic prospect of reams of denied and significantly delayed claims raises the specter of financial disaster or bankruptcy for many small practices.”

However, not all state medical societies are taking such a grim view of the transition.  The Tennessee Medical Association (TMA) wants to help its healthcare providers accept the inevitable, and is offering hands-on workshops and resources for providers who still feel unprepared. 

“We’ve known this was coming for a long time, but many providers have postponed or abandoned their readiness because of the repeated governmental delays,” TMA President Dr. John W. Hale, Jr. chidedin a press release.  “The implementation deadline is finally here and we do not anticipate that it will be delayed again. We want to do everything we can to help Tennessee’s physician community avoid business interruptions by giving them the resources they need to transition smoothly.” 

“Medical practices have been exposed to all the ICD-10 lectures and overview material they can stomach," added TMA CEO Russ Miller.  "Now is the time to make sure billing and coding personnel are ready. October 1 is rapidly approaching. We are offering hands-on coding camps to let people practice the actual exercises they will have to use on a daily basis, specific to their medical specialties.”  

Meanwhile, AHIMA has launched an online campaign to oppose the grace period legislation introduced by Representative Gary Palmer.  “With no official repercussions for inaccurate coding the door is wide open for both improperly paid claims at best and rampant fraud at worst-since proper payment of claims depends on accurate coding,” says AHIMA in a letter it urges stakeholders to send to their Congressional representatives.

“Coverage determinations and validation of medical necessity of healthcare services depend on codes submitted on claims for reimbursement; this bill is written in a manner that leaves the door open for up coding and possibly outright fraud,” the missive adds.

But the medical societies remain unconvinced.  If ICD-10 must go forward, they write, it should do so with a two-year period during which providers could not be penalized for technical malfunctions or coding mistakes or subject to audits.  Medicare should also deliver advanced payments to providers to offset any financial disruptions from ICD-10 implementation, the letter adds.

“We remain steadfast in our belief that the ICD-10 coding system offers no real advantages to physicians and our patients — and certainly no advantages to justify the time and expense the entire health care system has invested in this transition,” the societies reiterate. “Even if ICD-10 were ‘the best thing since sliced bread,’ its forced implementation would not be worth the extensive disruptions in patient care that surely will come without the grace period.”

“The reduced productivity alone will cost physician practices hundreds of thousands of dollars and extend patient waiting times. We stand ready to work with you, the administration, and Congress to help you achieve this tremendously important goal.”

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