Everything involving the Centers for Medicare and Medicaid Services (CMS) is a moving target. But there’s no denying that ICD-10 is coming. It’s just a question of when.

Keep in mind that I am writing this article September 17, 2014. And I would not have been able to write it without the help of my friends at the MGMA Corporate office in Englewood, Colorado, including Robert Tennant, senior policy advisor, and Jeb Shepherd, senior government affairs representative with the MGMA Government Affairs division.

The ICD-10 delay gives us an opportunity to take low-cost, high-impact steps to prepare for the new code set. In spite of this time we’ve been given, (October 1, 2015 is the new compliance date) the Medical Group Management Association research suggests that overall industry readiness for implementation continues to lag. The results, compiled through the Association’s Legislative and Executive Advocacy Response Network, indicate that less than 10 percent of practices report making significant progress when rating their overall readiness.

As part of the MGMA ICD-10 advocacy efforts, MGMA strongly asserted that comprehensive end-to-end testing is a prerequisite to ICD-10 implementation. Through the hard work and advocacy of the MGMA, CMS has announced three separate testing weeks for conducting “acknowledgement” testing for claims using ICD-10 codes.

In my April, 2014 article in Memphis Medical News, “CMS Hasn’t Got a Clue,” I pointed out that challenges remain; a back-end link providing payments and automated account records to insurance companies have yet to be built and might not be completed before summer.

I quoted from Time, March 10, 2014; “CMS said this is mostly a headache for the insurance companies and providers.” (Thus passing the buck away from CMS.)

The wire services, on September 17 reported lax security: “HealthCare.gov, the health insurance website serving more than five million Americans, has significant security flaws that put users’ personal information at risk,” said the Government Accountability Office. It cited more than 20 specific security issues related to who can get into the system, who can make changes in it and what to do in case the complex network fails. (Remember growing up and being told, “Do as I say, not as I do.”?)

The CMS’ new deadline (extension) for implementing ICD-10 for physician practice adoption of the diagnosis component known as the “Clinical Modification (CM)” is October 1, 2015.

After that date outpatient claims will need to be coded with one of approximately 69,000 codes, an increase from 13,000 codes in ICD-9-CM.

CMS also indicated that all HIPAA-covered entities (providers, health plans and clearing houses) would be required to continue to using ICD-9-CM through September 30, 2015, even if they were already prepared to move to ICD-10.

CMS has agreed to comprehensive end-to-end testing that includes returning a remittance advice. The testing weeks will be November 17-21, 2014; March 2-6, 2015; and June 1-5, 2015.

CMS says, “We specifically hope designating these three weeks will help to generate an increased interest,” but reiterates that acknowledgement testing is permitted at any point prior to October 1, 2015.

Some of you may remember the Comedy Series, “Sanford and Son,” staring Redd Foxx, which ran from 1972 to 1977. In the TV series his wife, Elizabeth, was deceased. During the show if some event occurred that had an impact on him, Fred would hold his chest as if he’s having a heart attack, look up toward heaven and say, “Ut oh, this is the big one, hold on Elizabeth honey, I’m coming to join you.”

I hardly missed an episode of “Sanford and Son.”

You might want to hold your chest.

In 2008, MGMA worked with Nachimson Advisors, LLC, on a study, to try and come up with the ICD-10 cost impact on individual provider practices. In 2014, after a six-year period with a group of consultants, they noted a substantial change in those cost estimates.

To determine the practice variable, they estimated costs for small, medium and large practices. Individual practice size was based on variable factors such as specialty, vendor and software. To be consistent, this is how the size of the practice was defined.

A small practice is comprised of three providers and two administrative staff.

A medium practice is comprised of 10 providers, one full-time coder and six administrative staff.

A large practice is comprised of 100 providers, 64 coding staff comprised of 10-full time coders and 54 medical records staff.

The estimated costs for medical practices to convert to ICD-10 were released in 2008 and then again in 2014 as follows:

2008 Study

Small practice - $83,290

Medium practice - $285,195

Large practice - $2.7 million

2014 Study

Small practice $56,639 - $226,105

Medium practice $213,364 - $824,735

Large practice $2,017,151 - $8,018,364

Based on a few budgets of some of the practices I work with, using seven variables, the most outstanding cost was payment disruption. For each size practice, almost 50 percent of the costs in the budget were payment disruption.

About two years ago, in an article I wrote for Memphis Medical News, based on my understanding and after talking with some of my colleagues in different parts of the country, I said, “Set up a budget and I suggest you meet with your banker, because with all the pieces involved you absolutely have a cash flow issue with your practice that could be substantial.”

In light of this, the old cliché holds true for CMS, “Do as I say not as I do.”

Bill Appling, FACMPE, ACHE, is founder and president of J William Appling, LLC.  He is a national speaker, presenter and a published author.  He serves as an adjunct professor at the University of Memphis and is on the boards of Hope House and Life Blood.  For more information contact Bill at j.william.appling@outlook.com.