ICD-10 Delay: Practical Considerations

Yes, it is true. ICD-10 implementation has been delayed again, until at least October 1, 2015. By a voice vote in the House on March 27, followed by a passing vote in the Senate on March 31, President Obama signed the “Protecting Access to Medicare Act” into law on April 1. The bill effectively was the one year SGR “Doc Fix,” but Section 212 of this law, delaying ICD-10 implementation and apparently included to mollify some physician groups, was no April Fools’ Day prank. The dust has not yet settled on the ICD-10 delay, CMS has not yet commented on it and there has been relative industry silence so healthcare providers and other HIPAA covered entities are left wondering what to do.

The following checklist may help to assist you as implementation preparedness activities are revised and the industry waits on more definitive guidance from Health and Human Services as well as the Centers for Medicare and Medicaid Services. It is broken into some overall considerations, and then more specific ones by most major areas affected. It is not intended to be all inclusive, as each healthcare entity will have individualized needs, but is representative of what may be deemed appropriate to consider given the delay and the currently unknown revised implementation date.


  • Revise the overall project plan with a new timeline and potentially new tasks
  • Obtain individual stakeholder feedback
  • Maintain and build on what has been completed so far, but with a more relaxed timeline
  • Determine a revised overall target completion date, allowing time at the end for final adjustment, testing and training


  • Revisit the Project Plan and timeline
  • Revisit all areas, whether or not considered currently complete, as there will be some that need to be redone
  • Identify competing resources, current and future
  • Deliver an entity-wide awareness message
  • Revisit meeting schedules


  • Revisit the current budget as there may be identified cost savings
  • Revisit budget for 2015 for incremental cost not previously considered
  • Consider costs now likely to be incurred in 2016


  • Evaluate revised training needs and timelines
  • Allow for extra practice time for coders
  • Consider training needs and schedule for physicians and other clinicians
  • Consider training for replacement systems, as appropriate

Health information management

  • Continue staffing/hiring plans as coders are going to be just as hard to find in the coming months
  • Reconsider retention strategies
  • Reconsider productivity strategies
  • Revisit training needs and practice time
  • Consider system needs
  • Consider implementing/enhancing a CDI program

Information Systems

  • Consider the likely new/revised list of competing projects
  • Minimize system changes to the extent possible
  • Continue internal testing, but with a relaxed timetable
  • Formalize change management strategies
  • Track additional data elements that may require testing
  • If system replacements/upgrades/changes/additions had previously been placed on hold due to time requirements, revisit as the delay may afford a different decision

Vendor Management

  • Communicate with all vendors to assess their plans
  • Revise testing timeframes, as necessary
  • Evaluate benefit of revising systems, given the new timeframe

Payer Management

  • Communicate with all payers to assess their plans
  • Continue payer remediation efforts
  • Revise testing timeframes, as applicable

Patient Financial Services

  • Develop strong denial management program
  • Watch CMS announcements
    • LCDs were due out April 10, but so far have not been issued
    • Other announcements are sure to be forthcoming
  • Revisit staffing needs and timelines in patient registration and billing areas

Once all the areas in the project have been revisited, have stakeholders agree upon the new strategies and appropriately revise the project plan tasks and timelines. The revised project plan should then be presented to the Steering Committee for approval. After that, the revised plan can then be executed in an orderly and agreed upon manner.

Again, with the delay in ICD-10 implementation until at least October 1, 2015, there is much to be done and in many cases, much to be revisited. A well planned and thoughtful approach will help make implementation a much smoother transition.

Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, investment, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.

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