On March 31, Congress passed the Protecting Access to Medicare Act of 2014 (H.R. 4302). The Act focused on the Sustainable Growth Rate (SGR) and, for the 17^th time, suspended the annual proposed Medicare physician pay cut. The bill also included seven lines that changed the implementation date for ICD-10-CM and ICD-10-PCS from Oct. 1, 2014, to “not before Oct. 1, 2015.”

This action is like a stay of execution for many physician practices, but don’t breathe a sigh of relief yet. This does not mean ICD-10 is gone. It means we have at least 365 additional days to “get it right!”

The delay will give all of us—from the independent four-physician ED practice to the Centers for Medicare and Medicaid Services (CMS), and every electronic health record (EHR) vendor, billing company, clearing house, and payer—the needed time to master ICD-10 and to conduct end-to-end testing of documentation, coding, and billing processes and software.

By January, it was clear to those of us intimately involved with teaching ICD-10 that hospitals and physicians would experience a significant delay in payment after ICD-10 implementation due to untested software. Then, my own physician confided that it was six months after the federally mandated ICD-10–required change in electronic claims format (4010 to 5010) before he got his first payment. He admitted his personal savings, now gone, had kept his practice open and asked me how bad it would be after ICD-10. I was forced to increase my estimate for delays in payment from a conservative six to a more realistic 12 months. I advised my physician students to get a credit line equivalent to 12 months of operating expenses, just in case.

There will be a call for CMS to adopt a staged implementation: ICD-10-PCS, the procedure code set (PCS) that affects only hospitals for inpatient procedures, in 2015; ICD-10-CM diagnosis codes, which affect all providers in all sites, in 2016; and the external-injury cause codes, the butt of the jokes about burning waterski injuries and turtle bites, in or after 2017. This phased-in implementation would not affect physicians in the first year; enables physicians to master the reasonable medical codes in the second year; and, once the system is working well, adds the large number of injury-data codes to the mix in a subsequent year. Smaller bites of ICD-10 would be much less daunting and a stepped approach would mitigate fiscal disruption.

The ICD-10 delay does not change the need for accurate documentation of your patient’s diagnoses in ICD-compatible terminology accompanied by the comprehensive clinical information to support each diagnosis. Fifty percent of the documentation needed for ICD-10 is also needed for ICD-9.