HFMA’s Comment Letter on CMS’s Proposed Rule to Delay ICD-10

May 17, 2012

Marilyn Tavenner
Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-0040-P
P.O. Box 8013
Baltimore, MD 21244-8013

File Code: CMS-0040-P

Re: Proposed Rule: Administrative Simplification: Change to the Compliance Date for ICD-10-CM and ICD-10-PCS Medical Code Sets

Dear Ms. Tavenner:

The Healthcare Financial Management Association (HFMA) would like to thank the Center for Medicare and Medicaid Services (CMS) for the opportunity to comment on its proposal to change the compliance date for ICD-10-CM and ICD-10-PCS medical data code sets (hereafter referred to collectively as ICD-10) that was published in the April 17, 2012, Federal Register.

HFMA is a professional organization of more than 39,000 individuals involved in various aspects of healthcare financial management. HFMA is committed to helping its members improve management of and compliance with the numerous rules and regulations that govern the industry and the principles of administrative simplification.

Introduction
HFMA would like to commend CMS for its thorough analysis of scenarios related to ICD-10 implementation delay. While many of our members view the delay negatively, they do support a limited extension of the compliance date deadline. Below, please find our comments and concerns related to an implementation delay of ICD-10.

Delaying ICD-10
If CMS elects to delay ICD-10, HFMA strongly believes that it should finalize the proposed rule. The delay should last no more than a year and (as outlined in the proposed rule) apply to all healthcare entities (all applicable provider types, insurance plans, state Medicaid agencies, and Medicare) for both ICD-10-CM and ICD-10-PCS. Our members agree with the proposed rule’s analysis that attempting to delay implementation for only one type of healthcare provider or limiting the delay to the diagnosis code set would result in unacceptable financial and administrative burdens for all stakeholders.

Once the one year delay is finalized, HFMA strongly encourages CMS to adhere to it. While a one year delay will significantly burden providers who would have been ready, we believe a delay greater than two years would jeopardize implementation efforts.

ICD-11 Implementation
HFMA strongly encourages CMS to use the time between ICD-10 implementation and the development of ICD-11-CM and ICD-11-PCS to work with providers and other stakeholders to develop a detailed, clearly communicated migration plan. Part of this migration plan should include support for smaller providers to help them manage the transition.

HFMA looks forward to any opportunity to provide assistance or comments to support CMS’s efforts to implement ICD-10-CM and ICD-10-PCS. As an organization, we take pride in our long history of providing balanced, objective financial technical expertise to Congress, CMS, and advisory groups.

We are at your service to help CMS gain a balanced perspective on this complex issue. If you have additional questions, you may reach me or Richard Gundling, Vice President of HFMA’s Washington, DC, office, at (202) 296-2920. The Association and I look forward to working with you.

Sincerely,

Richard L. Clarke, DHA, FHFMA
President and Chief Executive Officer
Healthcare Financial Management Association

About HFMA
HFMA is the nation’s leading membership organization for more than 37,000 healthcare financial management professionals. Our members are widely diverse, employed by hospitals, integrated delivery systems, managed care organizations, ambulatory and long-term care facilities, physician practices, accounting and consulting firms, and insurance companies. Members’ positions include chief executive officer, chief financial officer, controller, patient accounts manager, accountant, and consultant.

HFMA is a nonpartisan professional practice organization. As part of its education, information, and professional development services, HFMA develops and promotes ethical, high-quality healthcare finance practices. HFMA works with a broad cross-section of stakeholders to improve the healthcare industry by identifying and bridging gaps in knowledge, best practices, and standards.