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MACRA 911: Physicians Urge MACRA Delay

The Medical Association joined the American Medical Association and numerous physician groups to urge the Centers for Medicare & Medicaid Services delay implementation of the Medicare Access & CHIP Reauthorization Act of 2015, which replaced the Medicare Sustainable Growth Rate, and ensure new federal reimbursement programs “reward physicians for the improvements they make to their practice and the quality of care they provide to their patients.”

MACRA has been sharply criticized by physicians because of its framework establishing payment incentives for physicians and other clinicians based on quality of care rather than quantity, or fee for service. This framework for determining care standards, or Quality Measure Development Plan, includes measures in six quality “domains” such as clinical care, safety, care coordination, patient and caregiver experience, population health and prevention, and affordable care. Physicians would be paid based on their quality and cost metrics.

CMS plans to base reimbursements in 2019 on physician performance beginning Jan. 1, 2017. The proposed start date is too early and will create significant problems for the launch of the MACRA programs, and physician groups are calling for a six-month delay.

Other recommendations include:

  • Provide more flexibility for solo physicians and small group practices, including raising the low-volume threshold
  • Provide physicians with more timely and actionable feedback in a more usable and clear format
  • Align the different components of MIPS (Merit-Based Incentive Payment System) into a unified program rather than four separate parts
  • Simplify reporting burdens and improve odds of success by creating more opportunities for partial credit and fewer required measures within MIPS
  • Reduce reporting thresholds for quality measures

According to a new Medscape Medical News survey, almost four in 10 physicians in solo and small group practices predict an exodus from Medicare within their ranks on account of the program’s new payment plan and its punishing penalties. Fifty-nine percent of physicians in practices with fewer than 25 clinicians also said they expect to receive a performance penalty as high as 4 percent under proposed regulations that implement MACRA. Only 9 percent of physicians in under-25 groups expect a bonus, with another 12 percent counting on no change in compensation. Roughly one-third of physicians in small practices said merger into larger groups promises to be the most likely fallout from MACRA.

If you would like to take part in the poll, click here.

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Could MACRA Be Delayed?

During a recent Senate Finance Committee hearing, CMS Acting Administrator Andy Slavitt hinted at the possibility the agency might delay the start date of the Medicare Access and CHIP Reauthorization Act, or MACRA. Under MACRA, CMS would begin measuring performance in 2017 for payments that begin in 2019 – a timeline that has been a huge concern for physicians that are still awaiting a final rule.

“Every physician in the country needs to feel like they are set up for success,” and to do that the agency “remain[s] open to alternative approaches,” which include later start dates, shorter reporting periods and additional methods to ease physicians into the program,” Slavitt said during the hearing.

With no official start date confirmed for MACRA, and a final rule expected to be published Nov. 1, physicians are on edge about the timing of this new program, which is set to replace the sustainable growth rate formula for physician payment adjustments under Medicare. The Medical Association joined the American Medical Association and numerous physician groups to urge CMS delay implementation of MACRA, and ensure new federal reimbursement programs “reward physicians for the improvements they make to their practice and the quality of care they provide to their patients.”

In his testimony, Slavitt conceded that small, rural and independent practices will struggle with the new rules, and a central theme emerging from the public comment period was the need to design a program with special consideration for these groups.

“They do not have the resources of larger groups and each new administrative requirement takes time away from patient care,” Slavitt said.

He said another central theme from the 4,000 formal comments CMS received asked that CMS look for flexibility to allow physicians, other clinicians and their communities time to learn about and prepare for the sweeping changes.

“While the quality payment program builds on programs that should be familiar to clinicians, we understand new rules require adjustment and preparation,” Slavitt said.

Slavitt said CMS would consider numerous approaches to help delay and soften the blow of MACRA going live, including alternative start dates and shortened reporting periods. CMS is also looking into ways to reduce reporting burdens and eliminate reporting where physicians have consistently performed well.

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MACRA 911: What Questions Should You Be Asking Right Now?

While there is still no official start date confirmed for MACRA, and a final rule expected to be published Nov. 1, physicians continue to be on edge about the timing of this new program, which is set to replace the sustainable growth rate formula for payment adjustments under Medicare. With November just around the corner, what questions should you be asking right now?

Unfortunately, nearly half of U.S. physicians are unfamiliar with the Medicare Access and CHIP Reauthorization Act of 2015, or MACRA, according to a new survey of 600 doctors by research and consulting giant Deloitte. Under MACRA, CMS would begin measuring performance in 2017 for payments that begin in 2019 – a timeline that has been a huge concern for physicians that are still awaiting a final rule.

The Medical Association joined the American Medical Association and numerous physician groups to urge CMS delay implementation of MACRA, and ensure new federal reimbursement programs “reward physicians for the improvements they make to their practice and the quality of care they provide to their patients.”

According to HealthcareFinanceNews online, there are some questions physicians should be asking about MACRA right now:

Who are your eligible clinicians and how are they structured?

MACRA isn’t just about physicians. The answer to this question is important to allow you to formulate a solid plan of action to determine whether you will use MIPS (be measured and paid based on quality, resource use, clinical practice improvement and Meaningful Use), or APM (a payment method with a time limit of six years).

How do you optimize MIPS reporting and performance?

Most physicians will start under the MIPS system until you decide what reporting system suits your practice best: what measures you would perform best on, whether you feel confident in your ability to perform well under these measures, and ultimately if you want to stay under just MIPS.

Should I participate in an APM, and do I want to do a MIPS APM or Advanced APM?

Look at what models are available in your area, as some are geographically based, and also what is available for application. There are application periods that need to be taken into account. One thing to remember if you go with a MIPS APM, a one-sided model that carries no direct risk, you still have to be building your capacity to take on risk even while maximizing your time as a MIPS APM.

How are you communicating your strategy to your organization, the clinicians you work with and to your community partners?

Everyone needs to be on the same page. The official, finalized rules will be published for implementation in November, at which point providers will be expected to quickly prepare for reporting in 2017. Those reports will determine reimbursement, and penalties and bonuses where applicable, in 2019.

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MACRA 911: Physicians Will Have More Flexibility

MACRA will begin on Jan. 1, 2017, and according to CMS Acting Administrator Andy Slavitt physicians will have more options to comply and avoid a negative payment adjustment in 2019.

The announcement comes after intense pressure from industry stakeholders and policymakers to ease implementation of the Medicare Access and CHIP Reauthorization Act, which is set to start Jan. 1, 2017. Just two months ago, CMS announced the agency was considering delaying the start date.

Now, CMS seems to be conceding a bit of ground by adding more flexibility to the MACRA program with four options for participation:

Option One: The first option is designed to ensure more physicians are prepared to participate in 2018 and 2019 and will enable clinicians to submit data to the Quality Payment Program, including data after Jan. 1, 2017, and still avoid a negative payment adjustment.

Option Two: The second option will allow participation for part of the calendar year. Physicians may choose to submit Quality Payment Program information for a reduced number of days. The first performance period could begin later than Jan. 1, 2017, and the practice could still qualify for a small positive payment adjustment. This option can include the submission of information on how the practice uses technology and what improvement activities are being used. Physicians will choose from a list of quality measures and improvement activities under the Quality Payment Program in this category.

Option Three: The third option will allow physician groups to submit information for the entire 2017 year on quality measures and could qualify for a modest positive adjustment.

Option Four: The fourth option is for physicians participating in an Advanced Alternative Payment Model in 2017. Instead of reporting quality data and other information, the law allows participation in an Advanced APM, such as Medicare Shared Savings Track 2 or 3 in 2017. Physicians that receive enough of their Medicare payments or see enough of their Medicare patients through an Advanced APM in 2017 would qualify for a 5 percent incentive payment in 2019.

These changes come in response to feedback on CMS’s April proposal for implementing the Quality Payment Program on how excessive reporting can distract from patient care; how to encourage new programs, such as medical homes; and the unique issues facing small and rural non-hospital-based physicians, Slavitt wrote in a blog post.

More details on these options will become available when CMS releases its final rule for implementing the Quality Payment Program, sometime before Nov. 1.

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Letter to the Editor: Ever Been Bitten by a Killer Whale?

Dear Editor,

Ever been bitten by a killer whale? Have you sustained burns while waterskiing? Been hit by a spaceship? Know someone who was sucked into a jet engine more than once? Though these sound bizarre, if a new and controversial medical coding system goes into place a year from now, those are exactly the kind of questions doctors across Alabama will soon have to ask patients in order to list a patient’s diagnosis and treatment plan.

When a patient is examined by a doctor, the patient’s diagnosis and treatment plan are “coded” by the doctor. Each diagnosis and prescribed treatment, everything from broken bones and sprained ankles to more serious incidents such as cardiac events and strokes, has a code number. These codes are established by the World Health Organization to classify diseases and other health-related problems.

The present list of codes being used, ICD-9 (International Classification of Diseases, 9th Edition), contains roughly 13,000 codes. While updates are periodically required to keep up with changes in medicine, the switch from ICD-9 to ICD-10 is massive, with nearly 70,000 new and oftentimes bizarre codes that will add little or nothing to the care of patients. Indeed, in most cases, it will require considerably more time than the current system to find the right code, taking away from the time a doctor can spend with his or her patient. Everyone involved in the delivery of health care who submits claims to insurance companies – from doctors to hospitals – will be affected.

In theory, these new codes could allow for better tracking of health threats, like infectious diseases. But, there’s no indication that switching coding systems will really improve the care of patients. Health care should be about the patient, not the paperwork.

The Medical Association of the State of Alabama believes there has not been enough testing of this new system, particularly in rural areas, like so much of Alabama. Do Americans really need a code for “hurt at the opera?”

Bizarre codes aside, this issue is quite serious and the stakes are high. Patients trust their physicians to diagnose and treat them to the best of their ability so the patient’s health can improve. But if physicians can’t find a code or put down the wrong code, insurance companies may delay or even deny necessary treatments.

While better testing by the federal government would ease some of the concerns my colleagues and I have regarding ICD-10, there’s little or no indication that this totally new coding system will improve delivery of health care. I can’t help but wonder whether the switch to ICD-10 might mirror the launch of Healthcare.gov, which technicians are still trying to debug. Patients can’t wait that long for their treatments.

While our medical coding system may need updating, now is not the time as the entire American health care system is still reeling from implementation of the Affordable Care Act. With the 2017 due date of ICD-11 right around the corner, we’ll be doing this all over again in less than three years.

“Head banging into wall, multiple encounters…” wonder if there’s a code for that?

Ronald Franks, M.D.
President,
Medical Association of the State of Alabama

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ICD-10: Headache for Doctors; Heartache for Patients

*Below is the letter Medical Association and President Ronald Franks sent to Alabama’s Congressional Delegation urging support to delaying implementation of ICD-10 until October 2017..

Jan. 7, 2015

Dear Alabama Congressional Delegation;

On behalf of the Medical Association of the State of Alabama and our more than 7,000 physician members, we urge you to support delaying implementation of the new medical coding system known as ICD-10 until October 2017.

Forced adoption of this new coding system, which is scheduled for Oct. 1, 2015, will require everyone in a medical practice who touches a patient’s chart – from the physician to the person submitting the claim to the insurance company – to learn four times as many new medical codes as the current system, ICD-9. While the 16,000 medical codes in ICD-9 are well-known, ICD-10 contains more than 68,000 diagnostic codes. There are more than 250 codes for diabetes alone, and with four times as many codes as ICD-9, the government and insurance companies will have four times as many reasons to use ICD-10 coding mistakes to deny medical care!

While spending more time with patients is what patients and physicians want, under ICD-10 we will instead spend more hours in front of a computer screen scanning 68,000 medical codes looking for the right one. Not only will ICD-10 have no direct medical benefit for patients, this mandate is also a tremendous financial burden for medical practices already operating on shoestring budgets. The U.S. is the only country implementing all 68,000 new codes and the only country tying a massive coding system to a complex billing system. Further, experts from the Centers for Medicare & Medicaid Services warn physicians may not get paid for three to six months due to ICD-10’s extensive and complicated implementation. With the likely improbably the system works properly by Oct. 1, 2015, medical practices can’t absorb such long delays in payment.

The transition to ICD-10 is expected to cost more than $1.64 billion over 15 years, with more than 40 percent of that expense coming from the cost of upgrading information technology systems for different participants including the government, insurance companies, physicians and hospitals. While many hospitals are in favor of ICD-10 implementation this year, the people treating patients and responsible for navigating all 68,000 codes – physicians – stand firmly against implementation and in favor of a two-year delay. Physicians will be hardest hit by ICD-10 since the massive cost of software and training is not as easy to spread over a small medical group as it is over an entire insurance company, hospital system or government agency.

Forced adoption of ICD-10 has very real consequences for physicians and the timing could not be worse, when financial strain on medical practices is at its highest point in history. As physicians struggle to implement costly electronic health records and meet stringent quality measures under Medicare’s Physician Quality Reporting System, at the same time we never know when Congress might allow the flawed Medicare SGR formula, or “doc fix,” to expire, further cutting already inadequate Medicare payments by 20 to 30 percent. While our patients want better care and society demands innovation, physicians are drowning under a tsunami of government regulations, and adopting ICD-10 this year will only add to the problem.

Please don’t force this on medical practices this year. Instead, help us by stopping mandates like ICD-10 that stretch our resources and limit the time we spend with our patients. With ICD-11 coming in the near future, we ask your support for a delay of ICD-10 at least another two years so we can change how it will be implemented to protect physicians and patients. We may find that skipping ICD-10 entirely and moving to ICD-11, which is more compatible with electronic medical records, makes more sense. Please tell Speaker Boehner, Chairman Fred Upton and Chairman Pete Sessions that delaying ICD-10 for two years is a priority.

Thank you for your consideration.

Dr. Ronald Franks
President, Medical Association of the State of Alabama

Cc: U.S. Sen. Jeff Sessions
U.S. Sen. Richard Shelby
U.S. Rep. Robert Aderholt
U.S. Rep. Mo Brooks
U.S. Rep. Bradley Byrne
U.S. Rep. Gary Palmer
U.S. Rep. Martha Roby
U.S. Rep. Mike Rogers
U.S. Rep. Terri Sewell

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Alabama Physician Lone ICD-10 Dissenter During Congressional Hearing

MONTGOMERY – As the lone voice for physicians in a room filled with insurance company and hospital representatives, Jeff Terry, M.D., a Mobile urologist, urged a Congressional panel not to implement a massive revision to medical coding known as ICD-10, which he believes could force doctors out of business and threaten patients’ access to medical care.

“The vast majority of America’s physicians in private practice are not prepared,” Dr. Terry told the U.S. House Energy and Commerce Health Subcommittee last week. “Physicians are overwhelmed with the tsunami of regulations that have significantly increased the work for our practices. Physicians are retiring early, which could leave countless numbers of patients without a doctor.”

Dr. Terry’s and most physicians’ viewpoint on ICD-10 is at odds with insurance companies and hospital systems, which can more easily absorb the cost of new technology, training and personnel that ICD-10 compliance will require. Small medical practices can’t shoulder the burden of this “costly unfunded mandate” so easily Dr. Terry, a past president of the Medical Association of the State of Alabama, said.

While the current medical coding system ICD-9 has 13,000 codes, ICD-10 contains more than 68,000 codes including more than 250 for diabetes alone. Though other countries have adopted ICD-10 already, the United States is the only one planning to implement all of the 68,000 new codes and link both a massive coding and complex billing system together.

Unless Congress takes action, ICD-10 will be implemented on Oct. 1, 2015, adding to the growing list of government regulations Dr. Terry said makes it more and more difficult to provide the quality care his patients want and deserve.

“It is harder and harder to keep the patient as the primary focus in our daily activities. ICD-10 is viewed as another expensive distraction with little demonstrated value to improving patient care. The huge costs certainly outweigh the very few benefits. Based on data from other countries, doctors will be forced to reduce the numbers of patients they see after ICD-10 is implemented,” Dr. Terry said.

View the press release

Watch Dr. Terry’s testimony.

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Flawed Implementation of ICD-10 Less than Six Months Away

*Editor’s Note: The following is a special editorial from Dr. Jeff Terry, past president of the Medical Association, who has closely followed ICD-10 and testified before Congress concerning the need to delay implementation to mitigate the negative effects on medical practices.

Please don’t discount the cry for help coming from more than 90 percent of the physicians in this country. Please don’t overlook the obvious as far as what ICD-10 will really do to patient care, physicians’ practices and the medical profession. Please understand that 90 percent of the ICD-10 proponents will gain tremendously financially from ICD-10 implementation. Finally, please understand that ICD-10, along with all the other government mandates on medicine simply further removes the patient from the center of the health care equation and it gives physicians less time to listen to, talk to, and examine the patient. We are placing the computer in the middle of the patient-physician relationship where it doesn’t belong.

Physicians are scared. They are barely keeping up with the new electronic medical record system. Many physicians have to learn four or five different EMRs because they practice at different hospitals. We can’t use our own words anymore to describe our patient’s condition, our diagnosis and our plan. All of our comments, physical findings, orders and plans for care must fit into computer templates and other artificial ways to document. Part of the problem is trying to teach a generation of older physicians how to use the computer; another part of the problem is many different computer vendors that still haven’t figured out the right way to do it; and the final part of the problem is a meaningful use system which is anything but meaningful that forces us to do unnecessary work. Once a physician invests in an EMR he becomes a slave to that particular system because it is too expensive for most to make a change.

Physicians understand that coding is for statistics and has nothing to do with our patient care and is certainly not accurate enough to do medical research with, yet these are arguments that CMS and others use to convince Congress of the need for ICD-10. Also please understand the biggest untruth, which is that we are behind the rest of the world because no one else in the entire world has even come close to implementing an ICD-10 system like our government has proposed! Physicians are sending a very strong message that the present implementation of ICD-10 is extremely flawed and doesn’t make any sense. Physicians are sending a loud message that Congress/CMS must change the implementation of ICD-10 or many physicians will find themselves leaving the medical profession (willingly and unwillingly) and thousands of patients will be left without a doctor.

The best solution to this ICD-10 problem is to do what H.R. 1701 and S 972 from last year ask for: Delay ICD-10 and at the same time have a non-biased committee study the problem and come up with answers in the next six months. The study is needed because there are also many unintended consequences of this change that will also adversely affect the medical profession and patient care that CMS has not addressed yet. I understand the political reality, and CMS may not want to do this because the pro ICD-10 coalition is working so hard to the one-day implementation on 10/1/15. If this is not possible, then CMS must figure out a way to have a two-year transition period where physicians gradually transition into ICD-10 without having their payments go to zero for several months. Perhaps allowing a dual system for three to four months to start off and then accepting “generic” ICD-10 codes and not requiring the more specific codes for a couple of years.

Please see this non-biased article in Modern Healthcare from April 10, 2015. It points out the fact that many are not yet ready, and I testified to the Health Care Subcommittee of Energy and Commerce that no matter how much time you give us we will never be ready for a one-day implementation. It is like asking someone to run a four-minute mile or to fly an airplane all by yourself without real-time practice. It is not logical to think that our profession can do this. There must be a transition period. The industry may say that they are ready and 80 percent will be able to do it. What about the other 20 percent? Let’s assume only 5 percent of doctors don’t get it right. That means we lose 5 percent of our profession because of a coding system that will not actually help in the day to day care of our patients. These doctors will go out of business and for each physician we lose there will be 2,000 patients looking for a new doctor. This will happen in the district of every member of our Congress. Is this what America wants? We can do better!

Now that SGR is fixed, ICD-10 will be organized medicine’s top priority. ICD-10 must be urgently addressed because uncertainty is not fair to anyone, and the present plan for implementation will mean disaster for patients, physicians and the medical profession overall.

W. Jeff Terry, M.D.
Past President, Medical Association of the State of Alabama
Chair, Alabama Delegation to the American Medical Association
Legislative Affairs Committee, American Urological Association
Member, The National Physicians Council for Health Care Policy

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Bill in U.S. House Would #StopICD10

Rep. Ted Poe (R-Tex.), supported by six of his Republican colleagues including Rep. Mike Rogers (R.-Ala.) and Rep. Mo Brooks (R.-Ala.), has introduced a bill to block the government-mandated transition from ICD-9 to ICD-10 diagnostic codes set to take effect Oct. 1.

Dubbed the Cutting Costly Codes Act of 2015, the legislation would prohibit the Secretary of Health and Human Services from requiring the medical community to comply with the ICD-10 codes and instead allow the U.S. Government Accountability Office to conduct a study by consulting with medical community stakeholders to determine steps to “mitigate the disruption on health care providers resulting from a replacement of ICD-9 as such a standard,” according to a new article from Medscape Medical News.

“The new ICD-10 codes will not make one patient healthier,” Rep. Poe said in a news release. “What it will do is put an unnecessary strain on the medical community who should be focused on treating patients, not implementing a whole new bureaucratic language.”

Critics of the legislation argue the legislation will go no further than its predecessor in April 2013, which failed to get out of committee. While the medical community made a concerted push to repeal the sustainable growth rate once and for all earlier this year, no such effort has been made to delay or suspend the implementation of ICD-10 in October.

Small physician practices, especially in rural areas, will be further stretched to afford the transition costs associated with ICD-10, where physicians that work for hospitals or large health care systems have the funding to stay afloat during the transition and have little to no desire to delay implementation, according to the article.

The Medical Association’s Past President W. Jeff Terry, M.D., has been extremely vocal on the consequences of implementation of ICD-10 on small physician practices – even being the lone physician to testify before Congress to voice concerns should ICD-10 be implemented later this year.

While the Medical Association supports Rep. Poe’s legislation and is working to build support in the Alabama Congressional Delegation for ICD-10 delay, physicians are encouraged to make plans to prepare for the mandated transition should ICD-10 delay efforts prove unsuccessful.

“ICD-10 is a government mandate that will actually put some physicians and some hospitals out of business if they are not able to comply with this mandate all on one day on Oct. 1,” Dr. Terry said. “How can the government put a physician who has dedicated his entire life to his profession out of business with a mandate that is almost impossible to comply with? It’s like telling the physician he will need to run a five-minute mile to stay in business. I don’t care if you give him one or two years to comply; there are some things that just can’t be done. It’s not fair to physicians or the patients who will lose their physicians. We need to have someone with reason sit back and figure out a better way to implement ICD-10 to protect our profession. The proponents of ICD-10 have not acknowledged this problem at all, and they don’t acknowledge the millions of dollars they will receive when ICD-10 is implemented. There is a very big conflict of interest in this argument and there is a tremendous amount of bad information being circulated to justify ICD-10 even by CMS itself. Congress must act on this issue and do the right thing.”

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ICD-10 Switch Will Cause Problems in the ER

Researchers found 27 percent of the 1,830 commonly used emergency room ICD-9 codes had convoluted mappings that could create problems with reporting or reimbursement. Further, they found that when they looked at more than 24,000 actual clinical encounters in the ER, 23 percent could be assigned incorrect codes if recommendations of the Center for Medicare and Medicaid Services were followed.

During the past two years researchers extensively reviewed how ICD-9 codes map to ICD-10 codes, not only for emergency medicine, but for other problematic areas, including pediatrics, patient safety reporting and long-term research. Some ICD-9 indicator codes translate well, but many more have convoluted mappings — and some simply don’t map at all.

In their latest study, the UIC researchers looked specifically at the codes used most often by emergency physicians, to see where problems may arise.

“Despite the wide availability of information and mapping tools, some of the challenges we face are not well understood,” Dr. Andrew Boyd, assistant professor of biomedical and health information sciences at UIC and principal investigator on the study, said.

Problems due to ICD-10 will be more widespread for independent physician groups that staff EDs and perform their own billing, according to the report. They will be overwhelmed by the amount of analysis and challenges in ICD-10, so say the study authors.

Worries remain over ICD-10, especially for small practices. According to a survey from NueMD, a billing and practice management software vendor, the level of concern about ICD-10, especially among small practices, is “a little too high for comfort.” Legislation currently pending in Congress, dubbed the Cutting Costly Codes Act of 2015, sponsored by Rep. Ted Poe (R-Tex.), and supported by six of his Republican colleagues including Rep. Mike Rogers (R.-Ala.) and Rep. Mo Brooks (R.-Ala.), is an intention to block the mandated transition ICD-10 set to take effect Oct. 1.

The bill would also prohibit HHS from requiring the medical community to comply with the ICD-10 codes and allow the U.S. Government Accountability Office to conduct a study by consulting with medical community stakeholders to determine steps to “mitigate the disruption on health care providers resulting from a replacement of ICD-9 as such a standard,” according to a new article from Medscape Medical News.

“The new ICD-10 codes will not make one patient healthier,” Rep. Poe said in a news release. “What it will do is put an unnecessary strain on the medical community who should be focused on treating patients, not implementing a whole new bureaucratic language.”

While the Medical Association supports Rep. Poe’s legislation and is working to build support in the Alabama Congressional Delegation for ICD-10 delay, physicians are encouraged to make plans to prepare for the mandated transition should ICD-10 delay efforts prove unsuccessful.

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