In a proposed rule issued this spring (pages 648-650), the Centers for Medicare and Medicaid Services indicated that it expected to set a new ICD-10 compliance date of Oct. 1, 2015. Now in new guidance, CMS is reiterating that the date will hold firm in a final rule coming soon.

The guidance, which explains when and why dual coding and dual processing of ICD-9 and ICD-10 claims will be necessary during the transition, is below:

“Discussions of ICD-9 and ICD-10 often include mention of the terms dual processing and dual coding. Different people use these terms to mean different things, but in general, dual coding or processing refers to the use of ICD-9 and ICD-10 codes at the same time. So, when can you expect to use dual coding and processing and when can’t you?

Testing to Prepare for ICD-10

“Dual coding and dual processing can be useful tools to prepare for ICD-10 by testing whether you are able to prepare, send, receive, and process transactions with ICD-10. However, ICD-10 can be used for testing purposes only before the compliance date; providers and payers cannot use ICD-10 in “live” transactions for dates of service before the ICD-10 compliance date.

Dual Coding and Dual Processing After the Compliance Date

“Following the ICD-10 compliance date, providers and payers must use:

* ICD-9 in transactions for services provided before the compliance date

* ICD-10 in transactions for services provided on or after the compliance date

“While providers and payers must be able to use both ICD-9 and ICD-10 codes after the compliance date to accommodate backlogs in claims and other transactions, they will not be able to choose to use either ICD-9 or ICD-10 for a given transaction. The date of service determines whether ICD-9 or ICD-10 is to be used.”

When Is the ICD-10 Compliance Date?

The Department of Health and Human Services expects to release a final rule in the near future that will include a new compliance date that would require the use of ICD-10 beginning October 1, 2015. The new compliance date would give providers an extra year to prepare. The final rule would also require the continued use of ICD-9 for services provided through September 30, 2015.

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