CMS Confirms 5010 and ICD-10 Rules’ Effective Dates

In notification to the U.S. House and Senate on Thursday, March 5, 2009, Don Johnson, Acting Director, Office of Legislation of the Centers for Medicare & Medicaid Services (CMS), notified the Congress that “[i]n accordance with the White House Chief of Staff’s memorandum of January 20, 2009 entitled ‘Regulatory Review,’ a determination has been made that the effective date will not be extended and the comment period will not be reopened for either of these rules.” The effective date for each of the rules is March 17, 2009. The memorandum CMS sent to Congress follows. Beginning next Monday, March 9, HIPAA.com will have a posting daily through March 17, 2009, related to the 5010 Final Rule. Earlier, this week, HIPAA.com outlined the Level 1 and Level 2 requirements of the 5010 rule.

Why ICD-10?

There were four main reasons that the federal government moved to ICD-10 as a code set standard: (1) ICD-9 dates to 1979 and its functionality has been “exhausted” and does not reflect “new and changing medical advancements”; (2) Parts of the ICD-9-CM were full, which required putting codes in “topically unrelated chapters,” burdensome for healthcare providers in a move toward more efficiency; (3) Insufficient detail opportunities: “[I]n an age of electronic health records, it does not make sense to use a coding system that lacks specificity and does not lend itself well to updates…

Classification Coding Systems

ICD-10 diagnosis and procedure codes are “classification coding systems” useful for conducting administrative transactions. SNOMED-CT® (Systematized Nomenclature of Medicine–Clinical Terms) is a “clinically complex terminology standard” designed for the primary documentation of clinical care that will enhance interoperability with electronic health record (EHR) systems.

Migrating to ICD-10

Under the final ICD-10 rule, all healthcare providers will utilize ICD-10-CM to code diagnoses beginning October 1, 2013. For procedure coding under the final ICD-10 rule, physicians and all healthcare providers other than inpatient hospitals will continue to use the current procedure coding standard: Current Procedural Terminology, 4th Edition (CPT-4) and the Healthcare Common Procedure Coding System (HCPCS). Inpatient hospital services procedures will be coded using ICD-10-PCS codes, which provide facility related procedure codes suitable to inpatient environments.

HIPAA Administrative Simplification: Modifications to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS

The final rule adopts modifications to two code set standards in the Transactions and Code Sets final rule that required compliance by covered entities on or after October 16, 2003. The new final rule, published in the Federal Register on January 16, 2009, modifies standard medical data code sets for coding diagnoses (ICD-10-CM) and inpatient hospital procedures (ICD-10-PCS). ICD-10-CM means International Classification of Diseases, 10th Revision, Clinical Modification for diagnosis coding, including the Official ICD-10-CM Guidelines for Coding and Reporting, as maintained and distributed by the U.S. Department of Health and Human Services (HHS).

New HIPAA Standard Transaction Rules Released

On Friday, January 16, 2009, the Office of the Secretary of the Department of Health and Human Services published in the Federal Register final rules pertaining to: Health Insurance Reform; Modifications to the Health Insurance Portability and Accountability Act (HIPAA) Electronic Transaction Standards (74 Federal Register 3295-3328); and, HIPAA Administrative Simplification: Modifications to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS (74 Federal Register 3328-3362)

Final ICD-10 Rule

This final rule adopts modifications to two of the code set standards adopted in the Transactions and Code Sets final rule published in the Federal Register pursuant to certain provisions of the Administrative Simplification subtitle of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Specifically, this final rule modifies the standard medical data code sets (hereinafter “code sets”) for coding diagnoses and inpatient hospital procedures by concurrently adopting the International Classification of Diseases, 10th Revision, Clinical Modification (ICD–10–CM) for diagnosis coding, including the Official ICD–10–CM Guidelines for Coding andReporting, as maintained and distributed by the U.S. Department of Health and Human Services (HHS), hereinafter referred to as ICD–10–CM, and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD–10–PCS) for inpatient hospital procedure coding, including the Official ICD–10–PCS Guidelines for Coding and Reporting, as maintained and distributed by the HHS, hereinafter referred to as ICD–10–PCS. These new codes replace the International Classification of Diseases, 9th Revision, Clinical Modification, Volumes 1 and 2, including the Official ICD–9–CM Guidelines for Coding and Reporting, hereinafter referred to as ICD–9–CM Volumes 1 and 2, and the International Classification of Diseases, 9th Revision, Clinical Modification, Volume 3, including the Official ICD–9–CM Guidelines for Coding and Reporting, hereinafter referred to as ICD–9–CM Volume 3, for diagnosis and procedure codes, respectively.

Proposed Rule for Electronic Claims Attachments

This rule proposes standards for electronically requesting and supplying particular types of additional health care information in the form of an electronic attachment to support submitted health care claims data. It would implement some of the requirements of the Administrative Simplification subtitle of the Health Insurance Portability and Accountability Act of 1996.

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