An Update on the ICD-10 Implementation Timeline

update ICD-10 HISEdit: ICD-10 implementation has been delayed until after Oct. 1, 2015

October 1, 2014 may seem like a long time for finishing preparations, but the timeline for ICD-10 implementation has already reached the point where many practices should be moving on to the next significant stage of development.  While some may feel this is overly aggressive, the Centers for Medicare and Medicaid Services suggests the following ICD-10 Implementation Timeline.

March 1, 2013

  • Large Practices, Small Practices, and Hospitals should begin high-level training for ICD-10 at this point in time.  This is particularly important for clinicians and coders and will form the basis for further testing later on down the timeline.  Clinical documentation, software updates, and similar elements should be ready to put into practice as part of the EHR changes.
  • Payers should be revising coverage policies to handle the ICD-10 codes and determine what changes may need to be made to contracts.

April 1, 2013

  • This date serves as a major advancement for all groups.
  • Large Practices and Hospitals should begin testing ICD-10 coding with the personnel most involved with overall coding practices. The new codes should be primarily used for the diagnoses that are used most frequently.  This will allow staff members the opportunity to frequently practice the new system throughout daily work while avoiding the burden of learning the codes for every diagnosis.
  • Small Practices should be doing the same at this point in the EHR timeline, but have until June, 2013 to begin.
  • Payers should focus on testing all ICD-10 systems to ensure that all elements are working properly.  Coding and technical staff should be at the forefront for this phase of development.
  • All groups should review their reports for accuracy and ensure that all elements are being recorded properly.  If they are not, this should be fixed as soon as possible.

June 1, 2013

  • This is the latest point at which Small Practices should begin interior testing of ICD-10 codes.  All other groups should be several months into the testing, and broadly speaking, earlier is generally better than later for the commencement of testing.

October 1, 2013

  • This date begins the next major phase of testing and implementation for the ICD-10 system, focused on different systems linking together and more exterior than interior testing of all system elements.
  • Large Practices and Hospitals should begin testing claims and transactions using ICD-10 codes with business partners (payers, billing services, and so on). 
  • Small Practices, as above, should be doing the same.  If necessary, this step can be postponed until January 2014, but partners may prefer that testing commence sooner rather than later.
  • Payers should be ready to receive transactions from providers using ICD-10 codes.
  • Problems may still exist at some point within the overall coding software, and this step is one of the times most likely to generate problems between incompatible EHR systems.  The system receiving should be ready before the system sending the information, so payers may wish to take the step of signalling the point at which they are ready to begin and have practices begin submissions only then.
  • If systems fail, which is a realistic possibility between software that has not interacted before, backups using the old system may be necessary to use while the updated systems are fixed by the technical support personnel assigned to them.  All groups should be ready to use the old system as a temporary measure just in case.  Payers in particular should expect that smaller providers may begin submitting information later than larger ones.

January 1, 2014

  • This month is the last point in which Small Practices should be ready to begin submitting information to payers and other partners using the newer systems.  Any further delays will be extremely problematic for the EHR timeline.


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