Rex Stanley, RN, president of Alpha II, which develops data content and rules engines that drive diagnostic coding, claims editing and adjudication, suggests brokers begin familiarizing themselves with the sheer amount of work that's taking place behind the scenes at the carrier level.

"Everybody is at different stages of readiness," Stanley notes, although most of the large payers have indicated they were prepared for the Oct. 1, 2014, transition date. "Almost all of those payers have had to put together a team to train all of their people on new terminology and to work with vendors. When you push the implementation date back a year – and we don't know if it's just for a year, they could lengthen this delay out even more – what do you do with some of these people who the payers are paying tremendous amounts of money to manage technology and train teams to prepare for ICD-10? Do you dissolve that team and try to reform it six months later?

"Some of these teams have been in place for three or four years, and they've worked tremendously hard to be ready and spent a significant number of dollars on this transition," he continues. "And it makes me wonder how the dollars will roll down when payers try to reabsorb this cost that they were not expecting. If I were a broker, I would wonder, is this going to be reflected in cost? Are some of these costs going to be squeezed out of some brokers at exactly the time when the brokers might have to be spending more resources to work with their clients?"

Erik Newlin, the co-chair of the ICD-10 Assessment Workgroup at WEDI (the Workgroup for Electronic Data Interchange) and director of national standard consulting and government health care solutions at Xerox, says there's "an incredible amount of extra overhead that is carried through a delay. You might have acquired some analysis and testing tools through license. So you might have subscribed to that license for a year, and now, all of a sudden, you have to extend that license period with that vendor, so now you may have additional material costs right out of the gate. If you had a testing period that was scheduled for external testing that was to be completed by the original 2014 date, now what do you do with that staff? Can you reallocate them to something else? Or do you have to release them because you can't keep them on your books for eight or nine months? Each possibility comes with its own risks and complications that need to be carefully considered."

And the way the delay was worded might cause confusion, too.

"From what I understand, CMS has said they're not able to run both systems at one time," says Judy Waltz, a partner with law firm Foley & Lardner who specializes in health care compliance issues. "So I think the fact that you can't do either/or is going to cause real problems for people.

"It's an unfair delay because it penalizes the people who were really working hard to be ready," she adds. "I get that it's a big change and it's a lot of work, but from my perspective, it's pretty late in the day to put it off at this point."

However, although the delay is likely going to cost payers money, there are some silver linings that come wrapped in with the extra time.

"I think the larger the organization, the more likely they were prepared to meet the date. I do think every organization is probably sighing some relief, given the complexity of the project," notes Jay Dunlap, senior vice president at EXL, a health care operations management and solutions organization. "I think there are two ways of adopting ICD-10: One is just a compliance check-the-box, and even that level of effort is enormous – but the second way is to intelligently map the ICD-10 code so it adds value. The increased specificity of ICD-10 can bring clarity to the level of care assigned, payment details, how the member is tracked over time, and then outcomes can be associated with these more precise codes. So some of the larger organizations will take the time to make their compliance more elegant and bring more value to ICD-10 as it was designed to be used."

And Stanley also believes there could be a bright side.

"If everyone takes this as an opportunity for the late adapters to finish up, and if everyone will keep going, there's a chance that a lot of the hiccups could be worked out. And when it actually rolls out, it could cause fewer problems for brokers. The smoother this goes off, the fewer problems brokers will have. So there's a chance that for brokers, there may be sunshine out of this delay."