On September 9, 2008, the Federal Register published a CMS proposed regulation to change ICD-9 code sets to ICD-10-CM (diagnosis) and ICD-10-PCS (hospital procedures). HHS proposes to make the compliance date for this proposed rule for all covered entities October 1, 2011. Comments are due by 5 p.m. ET on October 21, 2008 . The regulation may be viewed at ICD-10 PDF and a CMS fact sheet may be viewed here at CMS Fact-Sheet . Based on conversations with IHS, these changes will have a negative impact in Indian Country in the areas of training and loss of productivity during the change over period. There is also a concern regarding the upgrading of software and hardware to facilitate the change, IHS indicated that if a Tribe were using RPMS then IHS would take care of the upgrades. If, however, the Tribe were using off the shelf commercial software then the Tribe would be responsible for the upgrade cost. Other considerations are the following: Possibility of a delay in reimbursement during the transition, which will affect revenues Probability of having to have both ICD-9 and ICD-10 systems for an extended period of time in order to handle unpaid claims, contested claims or other related issues A risk of increased unpaid or improperly paid claims because improper coding with the new system NIHB believes that it is important that all concerned parties should submit comments on these proposed regulations. Not just because of the impact the changes will have, but also to put the thoughts and opinions from Indian Country on the record. The more comments submitted the more consideration CMS would give to those concerns. In order to assist in this process we have attached a template letter that may be used as is, or modified to suit your circumstances. The comments must be submitted no later than 5 p.m. ET on October 21, 2008. We apologize for the short notice and intend to give more timely notices in the future. You may submit the comments electronically by: Going to www.regulation.gov and Type “8-12-08” in the search box and click on “go.” Scroll down until you see “HIPAA Administrative Simplification: Modification to Medical Data Code Set Standards To Adopt ICD–10–CM and . . . .” just below it click on “Send a Comment or submission.” Then follow all the instructions. (when commenting please refer to file code CMS-0013-P) Or if you prefer, by regular mail: You may mail written comments (one original and two copies) to the following address ONLY (remember to allow sufficient time for delivery by 5 p.m. October 21, 2008): Centers for Medicare & Medicaid Services Department of Health and Human Services, Attention: CMS-0013-P P.O. Box 8016 Baltimore, MD 21244-8016 By express or overnight mail: You may send written comments (one original and two copies) to the following address ONLY Centers for Medicare & Medicaid Services Department of Health and Human Services, Attention: CMS-0013-P Mail Stop C4-26-05 7500 Security Boulevard Baltimore, MD 21244-1850 If you have any questions please contact John Johns, NIHB Federal Regulations and Policy Analyst, at 202-507-4070 or jjohns@nihb.org .


Continue here: Important Information on Proposed Regulation to Change Code Sets (CMS-0013-P)