The American Health Information Management association, in a comment letter on the April 17 proposed rule to delay ICD-10 implementation by one year, seeks guarantees that there will not be further deadline extensions.

AHIMA in the letter to the Centers for Medicare and Medicaid Services and HHS Secretary Kathleen Sebelius, makes clear its position continues to be that there should be no delay in the present ICD-10 deadline of Oct. 1, 2013, and any such delay should be short.

“Therefore, if a delay is inevitable at this point, AHIMA urges that such a delay be limited to the one year stated in the proposed rule to limit financial and information losses, and HHS should make certain that all covered entities understand that: HHS and CMS fully intend to implement and use the ICD-10-CM/PCS code sets effective October 1, 2014; and the October 1, 2014, compliance date will not be extended and those that fail to comply will be penalized for their inability to use the new code set.”

Other recommendations include:

* CMS should take the lead in testing ICD-10 during the next 18 months as many entities expect to be ready to test by late 2012,

* The Office of the National Coordinator for HIT should ensure all certified electronic health records in 2014 include and facilitate use of ICD-10,

* Regional extension centers should be trained in helping their clients implement the new code sets,

* CMS should consider using its quality improvement organizations to assist providers in implementing and testing ICD-10, and

* With ICD-11 around the corner, HHS should implement an education and awareness initiative to explain the migration of terminologies and classifications expected during the next 10 years.

The comment letter is available here.

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