Beginning October 1, 2015, physicians will be required to utilize ICD-10 for claims. ICD-10 will replace the 35-year old ICD-9 diagnostic system. According to Acting CMS Administrator Andy Slavitt, “ICD-10 will set the stage for better identification of illness and earlier signs of epidemics, such as Ebola or flu pandemics.”
The task of converting to ICD-10 has proven nothing less than gargantuan for medical practices, and spurred intense lobbying from the American Medical Association (“AMA”) and other physician interest groups. As a result, on July 6, 2015, the CMS and AMA jointly released an announcement detailing efforts CMS will implement to ease the ICD-10 transition for physicians.
CMS Education Efforts include:
- Sending a letter in July to all Medicare fee-for-service providers encouraging ICD-10 readiness
- Completing the final window of Medicare end-to-end testing for providers this July
- Offering ongoing Medicare acknowledgement testing for providers through September 30th
- Providing additional in-person training through the “Road to 10” for small physician practices (CMS has a “Road to 10” website at http://www.roadto10.org/)
- Hosting an MLN Connects National Provider Call on August 27th .
CMS also promises to ease the transition with the following steps:
- Creating an ICD-10 Ombudsman, who will answer questions and monitor any issues that arise with ICD-10 implementation
- Medicare contractors will not deny claims billed under Part B solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner has used a code from the right family
- Advance payment of claims, if the Part B contractor is unable to process the claims within established time limits; these advance payments are conditional partial payments, requiring repayment, so long as conditions described in 42 C.F.R. Section 421.214 are met.
Strategies for physicians to ease the ICD-10 transition include:
- Don’t expect another implementation delay, and budget now for the necessary investments to convert to ICD-10
- Assess internal office capabilities now, to ensure all aspects have capability to code and bill using ICD-10; prepare all staff to “touch” the system for ICD-10 training, such as medical assistants who fill out lab forms requiring entry of a patient diagnosis code
- Create a communication team that clearly defines who is responsible to keep in touch with software vendors, health plans, and clearinghouses, in order to ensure smooth transition
- Master the codes that matter. Rather than try to learn all 155,000 codes, physicians should focus on the codes relevant to their specialty.
As always, a robust compliance plan goes a long way to avoid the hiccups inevitable in transitioning to a new coding system, as well as to prevent fraud and abuse issues moving forward. For specific advice or assistance addressing difficulties, providers are advised to seek experienced health care counsel.