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By Holly Cassano, CPC, CEO – Director of Coding Compliance and Education for Tactical Management, Inc.

ICD-10 Countdown – October 1, 2014 – 224 DAYS until Implementation

The AMA’s CEO Drafts Another Letter To Kathleen Sebellius, Still Calling For A Delay In ICD 10 Implementation 

The clock is ticking away on ICD 10 implementation and as each week passes, I wonder how many of my colleagues, along with providers, have begun preparations in advance of the October 1st deadline?  Are you one of the remaining holdouts that still thinks the AMA or CMS will rise up like a Phoenix from the ashes and suddenly declare that there is a new deadline?  I wouldn’t hold out hope for such an occurrence. CMS is operating Full Steam Ahead and Kathleen Sebellius is the conductor. 

In continued opposition, the AMA’s  CEO, James L. Madara, MD, has authored another letter of concern to Ms. Sebellius, as of February 12th, 2014.  Dr. Madara is still looking for a delay in implementation citing the following:  “AMA policy adopted by our House of Delegates calls for repealing ICD-10 for the simple reason that it is not expected to improve the care physicians provide their patients and, in fact, could disrupt efforts to transition to new delivery models.”  Dr. Madara has also conceded that in the event the delay is not considered, he and the AMA have offered several suggestions to Ms. Sebellius that include the following: 

  • Ø  Conduct true end-to-end testing with at least 100 different physician practices of varying sizes and specialties
  • Ø  Change CMS’ advance payment policy for Providers in good standing to allow for :


  1.                                I.            When a physician has submitted claims but is having problems getting the claim to reach the contractor due to problems on the contractor’s end
  2.                             II.            When a physician has not been paid for at least 90 days
  3.                          III.            When they attest that at least 25 percent of their patients are Medicare
  4.                           IV.            When they attest that at least 25 percent of their reimbursements are from Medicare 
  • Ø  Coding Requirements: 
    1. CMS adopt a policy for Medicare that provides a two-year ‘implementation’ period during which Medicare will not be allowed to deny payment based on the specificity of the ICD-10 code
    2. Will provide feedback to the physician on any coding concerns
    3. Will not be allowed to recoup payment due to a lack of ICD-10 specificity 

Click on the link below to read the letter in it’s entirety:


So what does all this mean to you and I?  It means that Coding professionals and Providers need to continue with their efforts towards ICD 10 Implementation.  It is highly unlikely that Ms. Sebellius or CMS will delay ICD 10 implementation, considering ICD 11 has been pushed back to 2017.    

So how can we prepare for ICD 10 and still be compliant with the October 1st deadline? 

Certified Coders and those preparing to sit for the CPC will have to take an ICD 10 Proficiency exam to keep their current credentials.  I also recommend providers who are proactive to also sit for the proficiency exam if they have the time, as it will provide a needed understanding for them of the different documentation requirements for ICD 10 codes. 

In a recent study of approximately 800 coders between March 2010 and October 2012 on  what the industry is calling “Biomedical Sciences” or just a fancy way of categorizing four of the core components of ICD 10: 

  • §  ANATOMY

Of the 800 or so that participated in the study, approximately 500 had results  which were included in the actual study.  These 500 tested on both a baseline audit and an advanced audit for a comparative sample.  The core group of 500 was comprised of coders that had either AHIMA or AAPC credentialing status and with/without advanced degrees. 

The study group reflected the following from just the baseline skill-set audit: 

Competancy Level: 

  • §  Medical Terminology 85%
  • §  Anatomy  77%
  • §  Pathophysiology  71%
  • §  Pharmacology 69% 

Pharmacology took a hit in level of core competency and that was for all 500 in the focus group.   None of the levels were stellar, but Medical Terminology at least was trending in the right direction. 

Key leaders in the Medical Coding and Billing industry recommend the following based off of these results: 


The leaders in HIM and Facility coding has suggested that for both Inpatient and Outpatient coders to do the following: 

  • §  16 hours of code training in ICD 10 


The leaders in physician office and outpatient coding, has suggested the following: 

  • §  For both outpatient or physician-based settings to focus on ICD-10- CM, but be sure to include the four core biomedical science groups indicated above as a part of their studies


Indicated that ICD 10 both CM/PCS, will require at least 50 hours of training for inpatient coders in order to have sufficient knowledge to code across ICD 10 in full.  CMS maintains that coding professionals will already have a core base in the following to guide them through the rigors of ICD10 implementation: 

  • §  ANATOMY

CMS deems that in order for a coder to correctly code across ICD 10, all coding professionals will have to maintain up-to-date  knowledge of core coding conventions in the ICD-10 system. 


Transitioning to ICD-10 for most who are certified will be a massive undertaking if you do NOT PREPARE.    I would equate it to watching Armageddon and we are all going out like Bruce Willis.   For me,  “An ounce of prevention is worth a pound of cure”,  take the time to ramp up your offense for ICD 10 and get ahead of the game.   Don’t get sidelined and find yourself scrambling to recover from a fumble. 

Key Steps  to achieve ICD 10 readiness: 


  • Ø  Review your knowledge base and identify any areas that you are lacking in
  • Ø  Review, Review, and Review some more about ICD 10 Coding conventions
  • Ø  Sign up for  FREE courses/webinars 

Final Thoughts 

It is wise to purchase a ticket on the ICD 10 that Ms. Sebellius is driving and, as with any new initiative, we will ALL be passengers on the same train.  One can choose to complain or debate ICD 10 Implementation,  but at the end of the day, it is wise to prepare and be the tortoise versus the cricket and leave that debate behind.  Don’t be the last to the finish line. Develop an ICD 10 buddy system for ICD 10 studies and network with a local AAPC or AHIMA chapter. 

For Free up to the minute ICD 10 news from ICD 10 Monitor, click on the following link:


The WHO (World Health Organization), has developed a great FREE interactive Electronic ICD-10-training tool, designed for the self-learner or classroom setting.  The modules consist of ICD-10 training  in all areas and allows the user(s) to tailor courses on an individual level if necessary or desired.  There is a downloadable instruction guide as well. 

For a great FREE ICD 10 course from the WHO click on the following link :