In a recent letter to HHS Secretary Kathleen Sebelius, the Medical Group Management Association is not advocating a quick determination of new implementation timelines for ICD-10.

MGMA offers seven recommendations that involve extensive cost/benefit analysis, pilot testing, analysis of overlapping initiatives, evaluation of additional code set approaches such as improving ICD-9 or mandating only inpatient use of ICD-10, staggered implementation dates with clearinghouses and insurers first and providers at least a year later, development of a single set of ICD-9/ICD-10 crosswalks, and certification of insurers, clearinghouses, and practice management/billing software.

“ICD-10 is expected to be one of the most significant changes the physician practice community has ever undertaken,” the association tells Sebelius. “This new code set will impact not only billing, quality reporting and other administrative transactions, but will also require changes to clinical documentation and workflow processes and necessitate extensive clinician training. The adoption of ICD-10 should not be considered without a revised implementation process in place. Failure to complete these critical steps will divert scarce intellectual, educational, and financial resources away from the adoption of HIT and other more critical patient care-focused endeavors.”

The letter is available here.

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