Providers still have time to prepare for ICD-10, say experts

There is still time to prepare for International Classification of Diseases, Tenth Revision (ICD-10) before the October 1, 2015 implementation date, presenters emphasized during the MLN Connects National Provider Call, “Countdown to ICD-10.” In advance of the implementation, just over a month away, presenters discussed coding and documentation requirements, billing and reporting guidelines, and testing results.

ICD-10

CMS adopted ICD-10-CM (Clinical Modification) for diagnosis coding and ICD-10-PCS (Procedure Coding) for hospital inpatient procedure coding to replace ICD-9. CMS initially set an implementation date of October 1, 2013 (see Final rule, 74 FR 3328, January 16, 2009) but later extended it to October 1, 2014. Pursuant to section 212 of the Protection Access to Medicare Act (P.L. 113-93), CMS established October 1, 2015, as the final implementation date for ICD-10 (see Final rule, 79 FR 45128, August 4, 2014).

ICD-10 preparation

The ICD-10 Quick Start Guide outlines five steps for providers to prepare for ICD-10: (1) make a plan by assigning target dates for completing each step; (2) train staff on the fundamentals of ICD-10 and identify the top ICD-9 codes that the provider uses; (3) update processes, including updates of hard copy and electronic forms; (4) talk to vendors and health plans to confirm their readiness for ICD-10; and (5) test systems and processes to verify ICD-10 readiness.

Stacey Shagena, a technical advisor for CMS, described CMS’s four-pronged approach to testing for ICD-10 and noted that the national acceptance rate for acknowledgment testing ranged from 76 percent in November 2014 to a high of 91.8 percent in March 2015. No system errors were found in the July 2015 end-to-end testing, and according to CMS, “testing demonstrated that CMS systems are ready to accept ICD-10 claims.”

Coding

Sue Bowman, senior director, Coding Policy and Compliance, for the American Health Information Management Association, noted that the determination of which code set to use depends on the date of service, not the billing date. Claims for dates of service on or after October 1, 2015, must be coded in ICD-10, while claims for dates of service before October 1, 2015, must be coded in ICD-9. The date of service for inpatient facility reporting is the date of discharge. The claim submission date is irrelevant in the determination of which code set to use. MLN Matters SE1408 describes how to handle claims that span October 1.

The increased specificity of ICD-10 codes requires more detailed clinical documentation, according to Nelly Leon-Chisen, Director, Coding and Classification, for the American Hospital Association. She advised providers to assess their current documentation practices and resolve documentation gaps.

Transition flexibility

CMS is, however, offering some flexibility to physicians and other practitioners paid under the physician fee schedule who are transitioning to ICD-10. For 12 months after the ICD-10 implementation, if a valid ICD-10 code from the right family (i.e., the ICD-10 three-character category) is submitted, Medicare will process the code and will not audit based on specificity. In addition, for quality reporting completed for program year 2015, physicians and other eligible professionals (EPs) will not be subject to the Physician Quality Reporting System, value-based modifier, or meaningful use penalties during primary source verification or auditing related to additional specificity of the ICD-10 code as long as the physician/EP used a code from the correct family of codes. An EP will also not be subject to a penalty if CMS has difficulty calculating quality scores due to the transition.

Assistance

Acting CMS Administrator Andy Slavitt announced that CMS is setting up and staffing an ICD-10 resource center, which will be operational in September, and named Dr. William Rogers as the ICD-10 ombudsman. The ombudsman, whose email address is icd10_ombudsman@cms.hhs.gov, will be a “one-stop shop” for providers, said Slavitt.

The fiscal year 2016 ICD-10 code set is available from the Centers for Disease Control and Protection.