HHS has also proposed adopting the updated X12 standard, Version 5010, and the National Council for Prescription Drug Programs standard, Version D.0, for electronic transactions such as healthcare claims. Version 5010 is essential to use of the ICD-10 codes.

"We agree strongly with the recommendation from the government's own advisory body, the National Committee on Vital and Health Statistics, that implementation of the 5010 transactions standards is a prerequisite to ICD-10. The two should not be implemented simultaneously," Jessee said.

CMS should wait at least three years after the conversion to 5010 before moving the healthcare industry to ICD-10, he said.

MGMA believes that CMS has not recognized the magnitude of this effort for each sector of the healthcare industry and the costs that medical groups will face to implement it, Jessee added.

Recent research by the MGMA Legislative and Executive Advocacy Response Network (LEARN) indicated that 95 percent of respondents in medical practices would have to purchase software upgrades for their practice management systems or buy all new software; 63.5 percent concluded that they would have to purchase code-selection software. In addition, 83.5 percent of LEARN respondents stated that they did not think public and private health plans would be ready to accept claims with ICD-10 codes by October 2011.

How would a switch to ICD-10 by Oct. 1, 2011, affect your organization? Send your comments to Editor Bernie Monegain at bernie.monegain@medtechpublishing.com.