New Compliance Date Issued for Transition to ICD-10

on Tuesday, 05 August 2014. All News Items | Case Management | Coding | Billing

In an August 1st MLN Connects™ Provider eNews, HHS issued the much anticipated Rule finalizing October 1, 2015 as the ICD-10 Compliance Date and as the saying goes, hopefully “the third time is the charm.”

ICD-10 Compliance Date Timeline

2009 ICD-10 Final Rule

Established Compliance Date for ICD-10 of October 1, 2013

2012 ICD-10 Delay Final Rule

2012 ICD-10 Delay Final Rule: Compliance Date changed from October 1, 2013 to October 1, 2014

2014 Protecting Access to Medicare Act

Secretary may not adopt ICD-10 under HIPAA prior to October 1, 2015

2014 HHS Finalizes New Rule

Compliance Date for ICD-10 now October 1, 2015

The Rule was published in the Federal Register on Monday August 4th. HHS emphasizes in this Rule that “we believe it is important to require implementation of ICD-10 as soon as the law permits because it will allow the industry to begin reaping the benefits of ICD-10 as soon as possible. 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. ICD-10’s granularity will improve data capture and analytics of public health surveillance and reporting, national quality reporting, research and data analysis, and provide detailed data to inform health care delivery and health policy decisions.”

In reading the seven pages of the Rule, this delay really comes down to the two key issues of time and money.


In a Friday August 1, 2014 MLN Connects™ Provider eNews – Special Addition, HHS indicated that “this new deadline allows providers, insurance companies, and others in the health care industry time to ramp up their operations to ensure their systems and business processes are ready to go on October 1, 2015.”


In this Rule, HHS prepared a Regulatory Impact Analysis (RIA) that includes the estimated financial impact of the delay.

*in 2014 Dollars
Source: Federal Register / Vol. 79, No. 149 / Monday, August 4, 2014 / Rules and Regulations / page 45128)
Table 1-Summary of Costs in 2015 of a 1-Year Delay in the Compliance Date of ICD-10*
(in millions)
(in millions)
(Average in millions)

Cost to Commercial Health Plans

$547 $2,786 $1,667

Cost to Medicare

$21 $32 $27

Cost to State Medicaid Agencies

$169 $182 $176

Cost to Hospitals & Large Provider Organizations

$422 $3,849 $2,136

Total Costs

$1,161 $6,850 $4,007

In addition to this delay providing time to ensure systems and business processes are in place, we encourage you to consider this delay as additional time to build a strong ICD-10 foundation through education for all key stakeholders within your facility.

Additional ICD-10 Resources:

For additional information about ICD-10, visit the">ICD-10 website.

Check the">ICD-10 Medicare FFS Provider Resources web page for the latest information and educational resources to implement and transition to ICD-10 medical coding.

Article by Beth Cobb

Beth Cobb, RN, BSN, ACM, CCDS, is the Manager of Clinical Services at Medical Management Plus, Inc. Beth has over twenty-three years of experience in healthcare including eleven years in Case Management at a large multi-facility health system. In her current position, Beth monitors, interprets and communicates current and upcoming Case Management / Clinical Documentation issues as they relate to specific entities concerning Medicare. You may contact Beth at This email address is being protected from spambots. You need JavaScript enabled to view it..

This material was compiled to share information. MMP, Inc. is not offering legal advice. Every reasonable effort has been taken to ensure the information is accurate and useful.

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