CMS has announced it will consider a delay in the implementation of ICD10 beyond the original date of October 1, 2013. How long will they extend it and what does it mean? Does CMS need more time, or are there political reasons to delay, maybe to make nice with the AMA? At this point, it appears there are more questions than answers about this major industry transition.

So, be truthful, were you going to be ready? Will you keep your timeline now or relax? Recent online surveys have revealed that a large majority of respondents are in favor of keeping the original deadline. Are these responses from people that were going to be ready anyway?

If you are guessing about the length of the delay, here are some possibilities:

1. Delay one year: This makes the most sense to me. CMS often aligns changes with their fiscal year.
2. Delay six months: This is a possibility, but this option might not be long enough to satisfy those who oppose the current timetable.
3. Delay the enforcement like HIPAA 5010 (3 months): Would this mean you have to justify your delay to CMS?
4. Stagger deadlines: Sure, why not add to the chaos?

A delay might be a reasonable action to take. Many may feel that other, parallel priorities already are interfering with preparation – like 5010 conversion, meaningful use, electronic health records, and denial management issues.

While everyone waits for answers and a decision from CMS, here are some things to do:

• Documentation (by physicians and others) will be very important when coding requires more specific information. Make this a focus of new processes and coordination among staff members who prepare and use it. A 3M senior consultant provided this list at the AHIMA ICD10 Summit of their top 10 documentation issues (with ICD10):
  
  1. Diabetes mellitus
  2. Injuries
  3. Drug underdosing
  4. Cerebral infarctions
  5. AMI
  6. Neoplasms
  7. Musculoskeletal conditions
  8. Pregnancy
  9. Respiratory/vents
  10. ICD-10-PCS—“the whole book”
• Training - Make a plan for training coders and other staff members. Now you will have longer to improve the ability of current staff instead of hiring/contracting or just being “short-handed.”