ICD-10 delay proposed, but that's not all
By now you have likely heard the Office of the Secretary of the Department of Health and Human Services (HHS) has formally proposed delaying the transition date for ICD-10-CM to Oct. 1, 2014. Good news for the practices that have not started or do not know when they will start preparing for ICD-10 (76 percent, according to today's reading of FPM's Reader Poll; vote and view the latest results in the left column of FPM's home page). You have an added year to get your plans in order and get caught up in preparing for this transition.
But this is not the only portion of this proposed rule that affects your practice. This rule also adds the implementation date for national unique health plan identifiers (HPID). By Oct. 1, 2014, all large health plans (i.e., payers) must apply for an HPID, just as physicians have applied for their national provider identifier (NPI). In addition, claims administrators, clearinghouses, and other entities involved in the claims process wil have the opportunity to adopt a national Other Entity Identifier (OEID). While this is good news in that it should eliminate some of the issues that occur with claims transmissions not routing to the correct claims administrators or payers, it will come with some costs to your practice.
By Oct. 1, 2014, your billing system must be equipped to include these numbers on your claims. Small health plans have until Oct. 1, 2015, to comply, which complicates matters because you may need to send the HPID on most but not all claims. If your software vendor or clearinghouse didn't fare well in the transition to the HIPAA (Health Insurance Portability and Accountability Act) 5010 electronic transactions standards, now would be a good time to discuss with them when they will start planning and working to achieve compliance with the HPID. The timeline provided in the proposed rule indicates that your systems should be ready to send test transmissions of claims with the HPID by April 1, 2013.
If you have comments on any of these proposals, the rule includes a comment period of 30 days from the date of publication in the Federal Register. Comments should include file code CMS-0040-P and may be submitted electronically on http://www.regulations.gov or in writing to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-0040-P, P.O. Box 8013, Baltimore, MD 21244-8013.
While you'll have an extra year to get ready for ICD-10, there is another sizable task on the to-do list – to prepare your claims systems to submit the HPIDs. I guess it is true that what one hand giveth, the other taketh away.
ICD-10: The gift of time
In February, I posted that the U.S. Department of Health and Human Services (HHS) had signaled its intent to delay implementation of International Classification of Diseases, 10th Edition (ICD-10), which was scheduled to happen on Oct. 1, 2013. Now HHS made it almost official.
HHS Secretary Kathleen Sebelius announced a proposed rule that would delay the compliance date for ICD-10 from Oct. 1, 2013 to Oct. 1, 2014. The proposed rule is subject to a 30-day comment period before HHS finalizes it and makes the proposed delay completely official.
As Cindy Hughes has noted in her most recent article in Family Practice Management, "While the delay may give you more time to prepare, it most certainly does not mean that you can postpone this work; it just means that if you start now, you might actually be ready by the new deadline." Cindy's article provides some great information in this regard, and you can find more information and resources on the American Academy of Family Physicians website.
So, HHS has provided the gift of another 365 days to prepare for implementation of ICD-10. Physicians and others would do wisely to use this gift to their advantage in getting ready. It seems unlikely that HHS will be this generous again in advance of the new deadline.
Comprehensive Primary Care Initiative resources
To help practices in the seven Comprehensive Primary Care Initiative (CPCI) markets announced this week, the American Academy of Family Physicians and TransforMED will offer a free webinar at 1 p.m. CDT on May 10, 2012. Bruce Bagley, MD, will present "CPCI Selected Markets: Preparing Your Practice for Participation." A webinar from Feb. 1, 2012, is also available for viewing – "The Comprehensive Primary Care Initiative: Qualification Requirements and How You Can Benefit." For more information about CPCI and these resources, visit http://www.aafp.org/cpci.
Comprehensive Primary Care Initiative: Coming soon to a market near you?
The Center for Medicare & Medicaid Innovation (CMMI) has identified the markets where it will test its Comprehensive Primary Care Initiative (CPCI), according to information posted yesterday on the CMMI website. CPCI, which was announced last fall, will test a payment model that offers physicians a monthly care management fee for each Medicare fee-for-service patient in their care as well as a share of any savings that the initiative generates. The following markets were chosen based on applications from payers:
- New Jersey,
- New York (Capital District/Hudson Valley Region),
- Ohio (Cincinnati/Dayton region),
- Oklahoma (Greater Tulsa region),
Approximately 75 practices in each market will be chosen to participate. CMMI will solicit applications from practices as soon as final agreements are signed with the participating payers, which include private health plans, state Medicaid agencies, and employers, as well as Medicare.
CPCI is a four-year initiative with a planned launch date this summer. If it is shown to improve quality of care and lower costs, CMMI has the authority to roll out the initiative nationwide. Read more about the initiative in Family Practice Management.
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