“HHS Secretary Kathleen Sebelius Announces Delay of ICD-10 until October 1, 2014” was the title of a CMS press release dated April 9, 2012. The news came in response to political pressures to postpone the original October 2013 deadline and ongoing industry concerns related to the bumpy transition to the new 5010 versions of electronic transactions. This paper outlines three key actions states can take to ensure the continuity of their ICD-10 transition efforts in the 'extra year.'

1. How Should Medicaids Respond to
the ICD-10 Postponement?
State Medicaid Agencies Face Challenges and
Opportunities as Regulatory Mandates and Coverage
Expansions Converge
This white paper contains data that shall not be duplicated, used, or disclosed in whole or in part without the express
permission of Cognosante. Copyright© 2012.

2. How Should MEDICAIDS Respond to the ICD-10 Postponement
October 2012
Contents
HOW SHOULD MEDICAIDS RESPOND TO THE ICD-10 POSTPONEMENT? ................................................ 1
MEDICAID CHALLENGES ................................................................................................................................ 1
WHAT CAN STATES DO WITH THE “EXTRA” YEAR .......................................................................................... 2
WHAT COGNOSANTE CAN DO FOR YOU.......................................................................................................... 2
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3. How Should MEDICAIDS Respond to the ICD-10 Postponement
October 2012
HOW SHOULD MEDICAIDS RESPOND TO THE ICD-10 POSTPONEMENT?
State Medicaid Agencies Face Challenges and Opportunities as
Regulatory Mandates and Coverage Expansions Converge
“HHS Secretary Kathleen Sebelius Announces Delay
of ICD-10 until October 1, 2014” was the title of a
CMS press release dated April 9, 2012. The news
came in response to political pressures to postpone the
original October 2013 deadline and ongoing industry
concerns related to the bumpy transition to the new
5010 versions of electronic transactions.
An August 24 announcement made the one-year
postponement official. The goalposts have been
moved, but now they are firmly set in place.
Medicaid Challenges
While the ICD-10 mandate applies to all health care
providers and health plans, public and private, the
additional layers of budget constraints and the expansion of coverage add unique challenges to State
Medicaid Agencies (SMAs) and the contractors who support them.
ICD-10 comes as a complicating – but necessary – addition to an environment also driven by:
Expansion of the covered patient population and the implementation of Health Information
Exchanges (HIX) under the Affordable Care Act (ACA)
Federally-mandated initiatives such as Health Insurance Exchange (HIE), and Electronic Health
Record (EHR) Incentive program under the American Reinvestment and Recovery Act (ARRA)
Updates to the Medicaid Information Technology Architecture (MITA) framework and “Seven
Standards” Enhanced Funding Requirements
While federal funding is
available for the various
initiatives, dynamics between
the federal and state
government can complicate
the financing picture as state
budgets and human resources
are strained in the current
economy. Moreover, as much
as the federal policies and
programs arise from a
common understanding of the
cost and quality benefits of
healthcare IT, the regulations
and directives do not connect
the dots. By necessity, the
integration and coordination
of the programs need to take
place at the state level.
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4. How Should MEDICAIDS Respond to the ICD-10 Postponement
October 2012
What Can States Do With the “Extra” Year
Following are three actions states can take to ensure the continuity of their ICD-10 transition efforts:
1. Continue efforts underway and allocate extra time for testing
While even the mention of a delay tends to impact forward momentum, SMAs should stay focused on
efforts underway, heeding the advice of CMS and industry experts to allocate the additional time for
testing. Some states are sticking to their original implementation schedule, planning for a full year of
provider outreach and end-to-end testing
2. Pursue funding from CMS
State funding will remain constrained, but CMS has encouraged SMAs to continue to submit Advanced
Planning Documents (APD) for review. Revisit prior plans and estimates to ensure you have resources in
place for the longer haul.
3. Integrate rather than isolate
ICD-10 projects, and any downstream effects of the delay, should be re-assessed in light of other
initiatives underway. New MMIS procurements, HIE, HIX and the enrollment of new beneficiaries under
the ACA expansion may all be impacted by the timing of ICD-10, both in terms of data requirements and
competition for scarce resources. Conventional impact analyses tends to proceed from the “as-is” state to
a “to-be” state; however, with many systems being simultaneously developed and deployed, there must be
an appreciation for how these multiple “yet to be” systems need to work together and how they will
enhance value. Active outreach and coordination between stakeholders in the implementation efforts is
key.
What Cognosante Can Do For You
Cognosante’s Standards Practice professionals have conducted and implemented full-scale ICD-10
remediation projects for SMAs and other health plans, both public and private. If you are starting late, we
have the been there/done that expertise to help you get up to speed quickly. For SMAs who have already
conducted an enterprise-wide ICD-10 impact assessment and are looking for support in the next phase of
the process, Cognosante has trained and experienced staff ready to assist with the critical resources
needed for a successful remediation effort.
Translation Services
The "bad news" of initial ICD-10 assessments is that there is no black box technical solution that
allows you to pour ICD-9 codes in on one side and instantly retrieve equivalent ICD-10s out the
other. The good news is that taking a hard look at medical policies, edits, audits and pre-auth rules
can yield cost savings and service enhancements. Cognosante’s “policy first” translation services
focus on using sophisticated tools to capture the meaning and clinical intent of your existing policies
and business rules so they can be consistently interpreted in both ICD-9 and ICD-10.
Testing/Test Planning/Approach
Unlike prior transaction-based HIPAA mandates such as NPI and 5010/D.0, the ICD-10 mandate
offers no "parallel processing" window. According to the rule, all dates of service (DOS) prior to the
Compliance Date must be ICD-9 and only ICD-9; all DOS on or after the Compliance Date must be
ICD-10 and only ICD-10. This industry-wide “Big Bang” implementation adds to the level of
complexity and reinforces the importance of hands-on, end-to-end testing across the enterprise and
with external trading partners. Cognosante’s industry savvy and testing services experience will help
you plan, establish and implement a testing solution that verifies the use of the new codes, not just
their length and format.
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5. How Should MEDICAIDS Respond to the ICD-10 Postponement
October 2012
Provider Outreach
The detail that all health plans, public and private, must remember is that all their diagnosis and
procedure data originates with providers - if providers don't capture it, health plans can't use it; if that
capture process isn't accurate, the data won't be reliable. It's understood that there will be a
transitional period during which both groups will become accommodated to working with the new
coding systems, but that only adds to the importance of working together prior to the transition. Most
Medicaid providers also serve patients covered by other health plans, such as Medicare, Blue Cross or
commercial plans, who may be providing ICD-10 training and guidance. But other providers, who
rely on Medicaid exclusively, may be looking to a particular SMA for virtually all of their ICD-10
guidance. Cognosante helps you leverage your existing communications resources to deliver timely,
accurate, and consistent provider messaging for the ICD-10 transition.
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