I haven’t mentioned 5010 recently as it seems to be the never-ending story. On March 15, 2012, a mere 16 days prior to the re-stated enforcement date of March 31, 2012, the Centers for Medicare and Medicaid Services (CMS) announced another HIPAA 5010 compliance delay in the enforcement of HIPAA 5010 standards until June 30, 2012.

As of the date of this post, I’m beginning to wonder if perhaps the solution to how and when the United States will transition to ICD-10 should be similar to what has occurred with the recent transition to 5010.

I sometimes think it is fun to sit back and think about alternative solutions – even when I know I don’t have all the facts and will never have the opportunity to be in the room to help make the final decision. So, just for fun here’s some commentary.

Right now we are looking at the “big-bang” effect by requiring the usage of ICD-10 diagnosis codes on every health insurance claim submitted by HIPAA-covered entities with a date of service of October 1, 2013 and forward.

So here is my suggestion, allow for a transition period. Under the current ICD-10 implementation requirement, claims with dates of service prior to October 1, 2013 will require ICD-9 codes, thus entities will need to be able support both ICD-9 and ICD-10 codes after the implementation date for a period of time. So, why not restate the compliance requirements?

Allow HIPAA covered entities that are ready to begin submitting and receiving claims with ICD-10 codes on October 1, 2013. While those that are not ready, can continue to submit claims with ICD-9 codes for a defined period of time. Thus, allowing those that are challenged with the current implementation date additional time to prepare and enable those that are able to implement to move forward – a transition period.

Oh, you can shoot a lot of holes in my suggestion. That’s ok, it is only a suggestion and it was fun thinking about it. Do you have a suggestion you would like to share?