July 22, 2014

CMS’ Proposed Rule Delays ICD-10 Deadline to October 2014

April 9, 2012, the Centers for Medicare & Medicaid Services (CMS) announced a proposed rule that delays the ICD-10 compliance deadline one year, to October 1, 2014. The proposed rule also adopts a standard for a unique health plan identifier (HPID), adopts a data element that would serve as an “other entity” identifier (OEID), and adds a National Provider Identifier (NPI) requirement.  

According to CMS, the introduction of the HPID under HIPAA standards for electronic health care transactions will provide increased standardization for providers who currently face improper routing, rejected transactions, difficulty in determining eligibility, and errors in identifying the correct health plan during claims processing. CMS reports that the HPID will allow for a higher level of provider automation without the use of multiple identifiers that differ in length and format.

The proposed rule adopts a data element to serve as the OEID for entities that are not health plans, health care providers, or “individuals” that need to be identified in standard transactions (e.g., third party administrators, transaction vendors, clearinghouses, and other payers). The proposed rule does not require such entities to obtain an OEID, but the entities may obtain and use an OEID in covered transactions. However, once an OEID is obtained, entities would be expected to use the OEID and disclose it upon request when engaged in covered transactions.

The proposed rule also outlines circumstances under which an organization covered health care provider must require noncovered individual health care providers who are prescribers to obtain and disclose a NPI. Organization covered health care providers that have as a member, employ, or contract with, an individual health care provider who is not a covered entity and is a prescriber must require such a prescriber to: (1) obtain an NPI, and (2) to the extent the prescriber writes a prescription while acting within the scope of the prescriber’s relationship with the organization, disclose the NPI upon request to any entity that needs it to identify the prescriber in a standard transaction.

Additional information on the proposed rule is available through CMS’ Fact Sheet andPress Release. Comments on the proposed rule are due May 17. 

©2014 von Briesen & Roper, s.c

About the Author

Meghan C. O'Connor, Health Care Attorney, Von Briesen Law Firm

Meghan O’Connor is a member of the Health Care Section and the Government Relations and Regulatory Law Section. She advises clients on a wide range of regulatory compliance, corporate, and transactional matters, including: HIPAA, HITECH, and other federal and state confidentiality laws; provider and vendor contracting; health care reform, Medicare, and Medicaid compliance; patient care and risk management issues; managed care; insurance regulation; and clinical integration and accountable care networks.

Prior to joining von Briesen, Meghan worked for the U.S. Department of...


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