The ICD-10 compliance date should, at minimum, be pushed back two years to Oct. 1, 2015, the American Medical Association contends in a comment letter to the Centers for Medicare and Medicaid Services.

The association, which in November took the position of aggressively opposing ICD-10, in the letter also opens to door for indefinite postponement of the code set.

For now, AMA says a two-year delay “is a necessary first step” and CMS can use the added time to conduct a cost-benefit analysis on physician practices. During that time, however, CMS should engage all relevant stakeholders to assess if an alternative code set is more appropriate, according to the association.

AMA notes that other countries have implemented a modified version of ICD-10, often with substantial government support. “If stakeholders cannot reach consensus on this matter during this two-year delay period, then the move to ICD-10 should be postponed indefinitely.”

The organization also urges better alignment of disparate program requirements, including Medicare electronic prescribing, Physician Quality Reporting System, and electronic health records meaningful use, to further reduce physician participation burdens. The comment letter is available here.

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