More members of Congress are speaking out about ICD-10 and it’s no longer just the usual suspects. This time, however, rather than calling for a delay or specific transition period, they may have introduced yet another alternative. 

Republican Texas Rep. Kevin Brady, who chairs the Ways and Means Subcommittee on Health, penned a letter signed by a baker’s dozen worth of U.S. Representatives and sent to acting CMS Administrator Andy Slavitt.

"With the HealthCare.gov debacle a vivid reminder of how technologically complex projects can go wrong despite agency assurances," the authors wrote, "we urge the agency to make information available to providers and the broader public that helps to address concerns."

The letter presents a fistful of suggestions for instilling confidence that the ICD-10 conversion not cause "widespread disruption." Those include: sharing a contingency plan for "how Medicare will process claims in the event CMS is unable to process ICD-10 codes" after the Oct. 1, 2015 compliance deadline, expanding voluntary end-to-end testing to more providers, educating providers on the resources and fallback options available to avoid claims disruption, and coordinating with non-Medicare health insurance payers.

And they offered one more suggestion that is perhaps most telling: "Indicate whether claims must include the ICD-10 diagnosis code with the highest level of specificity immediately upon the Oct. 1, 2105 effective date, or whether a clinically accurate but less granular code will be accepted. A period during which less specific codes are accepted while providers get accustomed to the new systems would be appropriate."

It’s worth pointing out that this was a letter rather than a proposed piece of legislation. Rep. Brady did not push for delaying ICD-10 but the language does sort of hint that perhaps CMS could decide on its own to either accept claims in ICD-9 or potentially grant providers another manner of grace period wherein it reimburses claims filed using unspecified codes under ICD-10.

That would be one way to get the whole country on ICD-10; those providers who are ready can, of course, start submitting ICD-10 codes immediately while the unprepared could also be using ICD-10 but not always using the most specific code possible while they are figuring out how to use the new classification system.

Is this even feasible? Or would it create a bigger mess than another delay?