ICD-10 Compliance Deadline Is Now October 1, 2015

August 5, 2014 | By Lawrence J. Tabas

Health care providers, health plans, and health care clearinghouses (“Health Care Entities”) are required to comply with ICD-10 (which stands for the International Classification for Diseases, 10th Edition) on October 1, 2015, according to a new final rule (“Final Rule”) released by the U.S. Department of Health and Human Services (“HHS”). This means that Health Care Entities must be ready for ICD-10 on October 1, 2015 in order to receive reimbursement for claims.

The Final Rule officially changes the ICD-10 compliance date from October 1, 2014 to October 1, 2015 and requires Health Care Entities to continue using ICD-9 through September 30, 2015. This implementation delay is yet another delay in a lengthy transition process. The Centers for Medicare and Medicaid Services (“CMS”) stated in a press release that “[w]hile many providers, including physicians, hospitals, and health plans, have completed the necessary system changes to transition to ICD-10, the time offered by Congress and this [Final Rule] ensure all providers are ready.”

According to CMS, ICD-9 is outdated. The Final Rule explains that “ICD-10 reflects the advances in medicine and medical technology” and that ICD-10 “provides greater specificity of diagnosis-related groups; improves quality measurement and reporting capabilities; improves tracking of illnesses; and reflects greater accuracy of reimbursement for medical services.”

Marilyn Tavenner, Administrator of the Centers for Medicare and Medicaid Services (“CMS”), stated that “ICD-10 codes will provide better support for patient care, and improve disease management, quality measurement, and analytics.” Furthermore, she said: “For patients under the care of multiple providers, ICD-10 can help promote care coordination.”  

To read the Final Rule click here.

To read the CMS press release click here.

The Health Law Gurus™ will continue to follow the transition to ICD-10. Please share your thoughts and experiences regarding ICD-10 with us and our readers in the comments section below.

About the Authors

Lawrence J. Tabas


Lawrence is the Chair for Obermayer’s Health Care Law Department and Election Law Practice Group. Lawrence’s Health Care Law legal experience includes the representation of Pennsylvania County governments in Behavioral Health Managed...

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