Society Comments on Proposed Implementation of ICD-10 and HIPAA Electronic Transaction Standards

On October 21, 2008, the Heart Rhythm Society submitted comments on the proposed rules issued by the Department of Health and Human Services (HHS) titled "HIPAA Administrative Simplification: Modification to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS" and "Health Insurance Reform; Modidications to the Health Insurance Portability and Accountability (HIPAA) Electronic Transaction Standards" as published in the Federal Register. View the Society comment letter (PDF, 140K) to HHS on the implementation of ICD-10 and the next generation of HIPAA transactions (ASC X12, Version 5010).

The Heart Rhythm Society supports the transition to the ICD-10 code sets and believes they will ultimately benefit the health care community, but is concerned about the profound impact the accelerated ICD-10 implementation timeline will have on the various covered entities required to use standard code sets for electronic transactions. The Society’s comments focused on the implications of rapidly replacing ICD–9 with ICD-10 in conjunction with implementation of 5010.

The transition to ICD-10 will be a massive and costly undertaking that will not only require extensive systems modifications, but will also require major changes in provider work flows and business processes, consequently, the October 1, 2011 proposed deadline for the healthcare industry to convert from ICD-9 to the ICD-10 code sets does not allow enough time.

The Society strongly supports the National Committee on Vital and Health Statistics (NCVHS) recommendation that calls for completion of 5010, which will take two years to implement, prior to beginning work on ICD-10, which requires three years to complete. View NCVHS recommendation (PDF, 60K).