Many white papers and blogs focus on benefits of ICD-10, but would be remiss if we didn’t also point out the punitive measures.  Health plans must file certification statements that they are in compliance with standards and operating rules by December 2013 including documentation, and provide proof of compliance.   In addition payers will have to provide documentation of proof of end to end to testing with providers.

These Sarbanes-Oxley like measures certainly should get your executive team’s attention if the benefits do not.


The laws have already been enacted. Organizations who do not comply may be subject to a fine of $1.00 per covered life per day if they do not meet the certification requirements.  These penalties double if inaccurate or incomplete information has been provided in the compliance documentation.   This means that a relatively small health plan with 100,000 members could be subject to a $2 million fine, per year.

See ICD-10 Assessments here.

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