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HHS Proposes One-Year Delay for ICD-10 Implementation; Standard National Unique Health Plan Identifier; Addition to NPI Requirements

April 13, 2012—The Department of Health and Human Services (HHS) April 9 released a proposed rule that would delay the ICD-10 implementation deadline one year, from Oct. 1, 2013, to Oct. 1, 2014.  HHS also proposes new administrative simplification provisions including establishing a national unique health plan identifier (HPID) and expanding the national provider identifier (NPI) requirements to traditionally non-covered providers, such as medical residents and interns.

Noting the ICD-10 implementation delay is due, in part, to provider readiness concerns, HHS cites results from a December 2011 Centers for Medicare and Medicaid Services (CMS) survey that indicated up to one-quarter of health care providers believed they would not be ready for the initial Oct. 1, 2013, compliance date.  According to HHS estimates, the delay would add 10 percent to 30 percent to the total costs providers are expected to pay to prepare for and transition to the new code set. 

The HPID would be used to identify a health plan that sends or receives covered transactions.  HHS estimates the HPID would save the health care industry between $1 billion and $4.6 billion through automation efficiencies and decreased administrative time spent between providers and health plans.  Related to the HPID, HHS proposes to adopt an optional “other entity identifier” (OEID) for entities that are not health plans, health care providers, or individuals such as third party administrators, clearinghouses, and transaction vendors.

HHS also proposes certain non-HIPAA covered individual providers, such as medical residents and interns, obtain an NPI and disclose it upon request to health plans or other entities when the provider prescribes medications that are filled by pharmacies. If finalized without modifications, health care providers would need to implement this requirement by April 7, 2013.

Comments are due May 17. The AAMC will submit comments. 


Will Dardani
Clinical Policy and Practice Specialist
Telephone: 202-828-0541


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