Although Rode, on behalf of AHIMA, applauded CMS in issuing the proposed rule, he also stated that it’s important to recognize the cost of such a conversion on some "financially burdened segments of the industry." Rode also urged CMS to provide information about how ICD-10 will affect the existing DRG and other Medicare prospective payment systems.
On behalf of AHIMA, Rode suggests that HHS do the following:
- Deliver a final rule as soon as possible so providers have a uniform compliance date with which to work
- Provide a three-year implementation period beginning with the effective date and that the compliance date should be the immediate October 1 date after that three-year period
- Freeze all ICD-9-CM, ICD-10-CM, and ICD-10-PCS code sets for one year prior to the compliance date
Rode also states that providers should not perform intensive coder training more than six months prior to implementation so coding professionals retain what they have learned. He also advocates for assistance from the federal government and health plans, such as a low-cost or interest-free loan, that will help offset adoption costs.