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6 Reasons Why ICD-10 Safe Harbor Is Dangerous for Healthcare Delivery

June 16, 2015

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The Coalition for ICD-10 has issued the following statement in response to the recent efforts to create a “safe harbor” for physicians, which would prohibit claims from being denied due to incorrect or unspecified ICD-10 codes, will result in dangerous consequences for the healthcare delivery system.

Multiple bills have been introduced in Congress that create a “safe harbor” for physicians by prohibiting claims from being denied “due solely to the use of an unspecified or inaccurate [ICD-10] subcode” (H.R.2247) or “for errors, mistakes or malfunctions” relating to submissions of ICD-10 codes (H.R. 2652). Supposedly, the goal is to ease physician’s transition to ICD-10 and reduce their financial risk as they become accustomed to submitting ICD-10 codes. Even though these bills are intended to respond to physicians’ concerns, the safe harbor appears to apply to all providers including hospitals. These bills are predicated on the assumption that the coding of ICD-10 diagnoses directly impacts physician payments and that ICD-10 coding will be a burden because required ICD-10 detail is not readily known or available in the medical record. Both of these assumptions are false.

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