ICD-1o and ICD-9 dual coding has been proposed in H.R. 3018 so called the Coding Flexibility in Healthcare Act of 2015 (Code-Flex) which aims to provide for a safe harbor period for the transition from  ICD–9 to ICD–10 by allowing dual coding for six months after the ICD-10 transition deadline. The bill was introduced by Representatives Marsha Blackburn (R-TN) and Tom E. Price (R-NC).

Code-FLEX defines the duration of the safe harbor period as follows:

“The transition period under subsection (a) shall begin on the first day in which the Secretary adopts such ICD–10 code sets as the standard for codes sets under section 1173(c) of the Social Security Act (42 U.S.C. 1320d–2(c)) and end 180 days after such date.”

Code-FLEX, if enacted, requires HHS to report to Congress 90 days after implementation of ICD-10 on the impacts the new codes are having on providers, patients and other stakeholders.

The bill has support from the Medical Group Management Association (MGMA) but we wonder how health plans who have prepared to retire ICD-9 centric systems and processes will respond.  Many including Medicare’s CMS adjudication systems are not designed to support ICD-9 after October 1, 2015.



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