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Important changes concerning replacement of current ICD-9 diagnosis codes with ICD-10 codes

Information for network providers in advance of the final decision by the U.S. Department of Health and Human Services (HHS) on the timeframe for replacing current ICD-9 diagnosis codes with ICD-10 codes.

ICD codes are the backbone of the healthcare system, and the new regulatory requirements for transitioning to ICD-10 will have significant implications for your practice. While Blue Cross and Blue Shield of North Carolina (BCBSNC) supports the move to ICD-10, it will be a massive undertaking. ICD-10 has more than 150,000 codes – a 500 percent increase over the 24,000 codes under ICD-9.

Under the proposed regulation recently issued by HHS, health plans and providers would be required to fully implement ICD-10 by October 1, 2011 – a much shorter timeframe than we are recommending. The comment period on HHS’ proposal ended in late October, and the final regulation may be issued as early as mid-November.

To illustrate the added complexity that providers may face when using ICD-10, we converted the enclosed model “superbill” created by the American Academy of Family Practitioner’s practice management journal from ICD-9 to ICD-10. As you will see, the superbill goes from 2 pages to 9 pages and this sample superbill is a conservative estimate. It should be noted that this is a mockup and is not intended to be considered as a final superbill – it is illustrative of what providers may need to use to code accurately with the five-fold increase in codes under ICD-10.

Current superbill ICD-9 Proposed superbill ICD-10 Converting an ICD-9 Superbill to ICD-10

BCBSNC has been working closely with a broad coalition of more than 60 provider organizations in Washington to educate HHS officials on the need for a workable timeframe for transitioning to ICD-10. We are concerned the proposed October 2011 deadline does not give providers enough time to redesign numerous systems and business processes to handle the new codes. Providers also will need to be trained on thousands of new codes (as demonstrated by the superbill) and may need to obtain new systems to assure use of the correct codes.

We, along with the American Medical Association and nearly all state medical societies, have urged HHS to give the industry more time to transition to ICD-10 in its final regulation. Specifically, we support the timeframe as recommended by the National Committee on Vital and Health Statistics (NCVHS) – a key advisory body to HHS – that allows:

  • Two years to complete the second generation of nine HIPAA transactions ("5010") – a prerequisite to ICD-10 – before beginning work on ICD-10 (not simultaneously); and an additional three years to complete ICD-10.

If the NCVHS-recommended process started in November 2008, industry would be finished by October 2013 – two years later than the HHS proposed timeframe.

As HHS readies its final regulation on ICD-10, we will continue to stress the need for an adequate implementation deadline. Once final regulations are issued later this year, we look forward to working closely with you to ensure a smooth transition.