Information You Can Use

Notices of Delay - Electronic Health Records and ICD-10

April, 2012

For those of you who are making the switch to electronic health records and endeavoring to qualify for the incentive payments being made available by Medicare and Medicaid (you know who you are), there is some good news in a proposed rule issued on February 23, 2012, by the Centers for Medicare and Medicaid Services ("CMS"). Specifically, CMS announced that providers who achieved the Stage 1 requirements in 2011 will have until 2014 to implement the Stage 2 requirements (previously, the Stage 2 implementation deadline was 2013). [1]

In another bit of good news, the U.S. Department of Health and Human Services announced on February 16, 2012 a further delay to implementation of the International Classification of Diseases, 10th Edition, diagnoses and procedure codes (ICD-10) from the then current implementation date of October 1, 2013. The new implementation date has not yet been announced. This situation is reminiscent to the postponement of a school exam - celebrate and put off until tomorrow what you can't do today anyway!

Contact Mark D. Aurand for more information.

1. By the way, if you are making the switch to electronic health records, make sure that you, or in many instances the vendors you have hired to assist you in this process, are implementing into your electronic medical records system all appropriate privacy safeguards, including basics such as unique log-in IDs and passwords (which are changed from time to time), re-log-in if the computer has been inactive for more than a few minutes, encrypted memory sticks, firewall protection and security software, and the like. While these precautions may in some instances be cumbersome, you will be happy you did put them in place if and when you inadvertently leave a laptop or memory stick in a cab or some other public area. This happens more times than you might think! Any such program should, of course, also include staff training and procedures for responding to a breach. If you have any questions concerning your privacy and security obligations, Davison & McCarthy can help.