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The Short Answer
In essence you may have three more months to work on getting up to speed with ASC X12 Version 5010 code compliance without fear of "enforcement actions," but it's really not that simple--and there's a catch .
The More Detailed Version
The compliance date stays the same: January 1, 2012 (that's just 6 weeks from this Sunday, the 20th of November). What's different is that CMS has decided to create a 90-day "Discretionary Enforcement Period " which, in effect, means that they will wait until March to "take enforcement action."
What's the Catch?
During the 90 day Discretionary Enforcement Period you are still subject to the filing of non-compliance complaints, and if you don't get your act together by March 31, you could be subject to some stiff fines from non-compliance during the period. In fact, the only real change here is that if you're found to 
be non-compliant during the 90 day period, you can avoid any enforcement action by clearly showing that you're making a good-faith effort to comply .
What if we're really behind the 8-ball?
CMS says they've taken this step because "industry feedback" has revealed that less than "a majority of covered entities would be able to be in compliance by January 1," so you have company if you are behind. And there may still be some hope for still more time to prepare. You can read more about it in the December PBN Minute, but several prominent industry groups are putting serious pressure on CMS to back off on the October 2013 deadline for ICD-10 compliance, citing the effects of the down economy and the number of simultaneous efforts being promoted by CMS over the same time period. This and the many entities unprepared for transition even to Version 5010 may prompt CMS to review its deadlines, but don't count on it!
The details . . .
To find out more, check out the announcement itself, and the frequently updated FAQs (three of them were updated in the hour it took to draft this update) regarding the announcement on the CMS website .
For more specific information about how the CMS announcement may affect your practice and what PBN can do to help, contact a PBN client liaison at or stop by PBN's booth at RSNA .
For more information and guidance on this and other issues that affect your bottom line, contact . . .
PBN Business Development, 800.288.4901,
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