New legislation that calls for a grace period or transition period to ICD-10 is misguided and could have negative impacts on implementation of the new code set, according to proponents of ICD-10.
A safe harbor would compromise the ability of Medicare to monitor quality of care, the Coalition for ICD-10 writes in a post on its website.
The coalition says recent bills asking for transition or grace periods focus on the assumption that coding in ICD-10 impacts physician payments and will be a burden on providers. These assumptions, the coalition says, are false.
In addition, a two-year transition period could be a massive risk when it comes to audits, Juliet Santos, ICD-10 principal consultant for Leidos Health, writes in an opinion piece at ICD-10 Monitor.
The comments are in response to a bill proposed by Rep. Gary Palmer (R-Ala.) that would provide a grace period of two years for providers set to transition from ICD-9 to ICD-10 this October. During the grace period, physicians and other providers would not be "penalized for errors, mistakes and malfunctions relating to the transition," FierceHealthIT previously reported.
That's in addition to legislation brought forth by Rep. Diane Black (R-Tenn.) that would require the Health and Human Services Department to offer end-to-end testing of the code set, as well as an 18-month transition period.
These bills, the Coalition for ICD-10 says, could:
- Restrict Medicare's ability to determine coverage, medical necessity and quality of care
- Ignore Medicare's "fiduciary responsibility to ensure proper payment"
- Raise fears about the possibility of fraud and abuse
- Encourage incomplete documentation
Santos adds that if Palmer's bill is passed, it will void any audit-protective effects of ICD-10.
The Centers for Medicare & Medicaid Services "surely cannot afford a bill that condones 'runaway costs' through lenient reimbursement strategies at a time when fraud and abuse seem to be so rampant in healthcare," she says.
However, despite the chance problems could arise from legislation that calls for a transition period, there are some who want to take it even farther--Rep. Ted Poe (R-Texas) recently introduced a bill to Congress that would ban ICD-10 outright.