The Medical Group Management Association is supporting another effort in Congress to enable ICD-9 or ICD-10 coding for six months following the ICD-10 compliance date on October 1.
Reps. Marsha Blackburn (R-Tenn.) and Tom Price, M.D. (R-Ga.) introduced H.R. 3018, which was referred to the House Ways & Means and Energy & Commerce Committees.
Under the bill, the Department of Health and Human Services would implement a transition period during which claims and related transactions “otherwise payable (or processed) by public and private payers shall continue to be processed and paid, as applicable, if submitted with ICD-9 codes.” The bill also would require within 90 days of enactment that HHS submit a report to Congress assessing the impact of ICD-10 on providers and individuals.
Several bills that would impose a transition period for ICD-10 have been introduced and not enacted, and time is short for action on this legislation with only 17 session days left before the compliance data. However, bills sometimes don’t have to be enacted to change policy as lawmakers and stakeholders put pressure on regulators to be more flexible, notes Robert Tennant, director of HIT policy at MGMA. “There’s various ways to get to the end zone.”
The Centers for Medicare and Medicaid Services, for instance, recently made several ICD-10 policy concessions in a deal with the American Medical Association that cover the Medicare program. Now, the lawmakers and MGMA seek more flexibility.
MGMA’s big worry is that large numbers of physicians through no fault of their own won’t be ready for ICD-10 because they have not received software upgrades in a timely manner and may have no way come October to submit ICD-10 claims, or they have been unable to adequately test with insurers.
In addition, a survey with close to 600 respondent practices and weighed to MGMA members found that found that 20 percent of the practices still submit 4010 formatted claims, three years after the ICD-10-supporting 5010 format was introduced. If larger practices never made the change, it is likely that many smaller ones also did not. The 4010 format cannot accommodate an ICD-10 claim, Tennant said.
Further, Tennant notes, compliance with the 5010 transactions set included a 6-month transition period.
In a surprise concession, the Centers for Medicare & Medicaid Services announced Monday that it would work with the American Medical Association on four steps designed to ease the transition to ICD-10.
Despite longtime disagreements on the topic, CMS will now adopt suggestions made by none other than the AMA with regard to the code set conversion. Those changes concern:
1. Claims denials. “While diagnosis coding to the correct level of specificity is the goal for all claims, for 12 months after ICD-10 implementation, Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family,” CMS officials wrote in a guidance document.
2. Quality reporting and other penalties. “For all quality reporting completed for program year 2015 Medicare clinical quality data review contractors will not subject physicians or other Eligible Professionals (EP) to the Physician Quality Reporting System (PQRS), Value Based Modifier (VBM), or Meaningful Use 2 (MU) penalty during primary source verification or auditing related to the additional specificity of the ICD-10 diagnosis code, as long as the physician/EP used a code from the correct family of codes,” CMS explained. “Furthermore, an EP will not be subjected to a penalty if CMS experiences difficulty calculating the quality scores for PQRS, VBM, or MU due to the transition to ICD-10 codes.”
3. Payment disruptions. “If Medicare contractors are unable to process claims as a result of problems with ICD-10, CMS will authorize advance payments to physicians,” AMA president Steven Stack, MD, noted in a viewpoint piece on the group’s website.
4. Navigating transition problems. CMS intends to create a communication center of sorts, including an ICD-10 Ombudsman, “to help receive and triage physician and provider issues.” The center will also “identify and initiate” resolution of issues caused by the new code sets, officials added.
“These provisions are a culmination of vigorous efforts to convince the agency of the need for a transition period to avoid financial disruptions during this time of tremendous change,” wrote Stack.
While AMA played a pivotal role in bringing about these CMS concessions, it was not the only party calling for a smoother conversion to the new code set.
Some members of the U.S. Congress have publicly suggested a dual-coding conversion period wherein CMS would accept and process claims in both ICD-9 and ICD-10. Instead of dual coding, CMS indicated that “a valid ICD-10 code will be required on all claims starting Oct. 1, 2015.”
So as things stand today, providers have to use ICD-10 come October – but CMS will be more flexible about denials and payments than it has previously suggested it would be.
The deadline for the ICD-10 coding transition is less than 100 days away and healthcare providers are scrambling to finish preparing for the implementation. The Centers for Medicare & Medicaid Services (CMS) continues to stress the need to be as prepared as possible for the coming ICD-10 coding transition.
Even though providers and payers have less than 100 days left, there is still time to get ready if one gets started immediately. CMS is helping providers who are behind in their ICD-10 coding transition preparations by offering an ICD-10 Quick Start Guide.
The five steps a provider needs to take right now if they haven’t begun preparing for the ICD-10 coding transition are:
1) Develop a plan
2) Train healthcare and coding staff
3) Update system processes and workflows
4) Discuss issues with vendors and health payers
5) Perform system and processing testing
It’s vital to set target dates for completing the steps outlined above. At the very beginning stages of making a plan, providers would benefit from downloading and obtaining ICD-10 codes via the CMS website. These codes are available in a multitude of formats including print and electronic either through practice management systems or upgraded EHR products.
CMS encourages providers to obtain access to the ICD-10 codes. Other formats that the ICD-10 codes can be retrieved through include code books, digital media like compact discs or digital video discs, online at cms.gov/ICD10 under the “2016 ICD-10-CM and GEMS” category, or even via smartphone applications.
Some common workflows and system processes that will be affected by the ICD-10 coding transition include patient registration or scheduling, clinical documentation, billing, coding, public health reporting, order entry, authorizations, and referrals.
Additionally, it’s vital to decide how one’s clearinghouse will assist in preparing providers for the ICD-10 coding transition. It may benefit some providers who are behind in their preparations to contract with a clearinghouse in order to test submitting the ICD-10 code claims. A clearinghouse can be useful when it comes to helping identify why claims were rejected as well as offering assistance in how to revise rejected claims.
“Practices preparing for the October 1, 2015, ICD-10 deadline are looking for resources and organizations that can help them make a smooth transition. It is important to know that while clearinghouses can help, they cannot provide the same level of support for the ICD-10 transition as they did for the Version 5010 upgrade,” CMS stated in a pamphlet. “As you prepare for the October 1, 2015, ICD-10 deadline, clearinghouses are a good resource for testing that your ICD-10 claims can be processed and for identifying and helping to remedy any problems with your test ICD-10 claims.”
In order to be properly reimbursed, healthcare providers will need to be ready for the ICD-10 coding transition by October 1. In the meantime, it’s important to continue using ICD-9 codes for all services rendered before the deadline.
Is your Health IT partner holding your hand through the ICD-10 transition? Are you stuck in a product that’s not being updated to handle the new code set, and in need of a new solution that will be ICD-10 ready. Contact DAS today and let us help you navigate this new phase of healthcare.
With the October 1 ICD-10 deadline rapidly approaching, another member of Congress has introduced legislation that would establish a “grace period” following the compliance date during which providers could not be denied Medicare/Medicaid payments because of coding errors.
Rep. Gary Palmer (R-Ala.) has sponsored the “Protecting Patients and Physicians Against Coding Act” (H.R. 2652) which calls for a two-year grace period so that providers can “focus on patient care instead of coding and receiving compensation for their care while ICD-10 is being fully implemented.” With ICD-10’s five-fold increase in codes compared to ICD-9, Palmer warned that the code switchover creates significant administrative challenges for rural and small town providers in particular, who lack the resources to fully prepare for the ICD-10 implementation.
As a result, the congressman said he is concerned that some providers will not receive payments for “what they are owed” due to current law which could prevent them from being reimbursed by the Centers for Medicare and Medicaid Services “because of simple coding mistakes or systemic failures.” According to Palmer, a two-year grace period “will provide time for the system to be implemented and kinks worked out without threatening the quality or availability of healthcare for Americans who live in small towns or rural areas.”
Likewise, Rep. Diane Black (R-Tenn.) recently introduced her own ICD-10 legislation seeking to institute an 18-month transition period beginning October 1, during which no claim submitted for payment by a provider would be denied as a result of using an unspecified or inaccurate code.
While Black’s bill only has five cosponsors, Palmer’s bill has 32 original cosponsors—including House Budget Committee Chairman Tom Price, M.D. (R-Ga.) and Rules Committee Chairman Pete Sessions (R-Tex.)—and has been referred to the Committees on Energy & Commerce and Ways & Means.
However, the American Health Information Management Association opposes Palmer’s bill on the grounds that the ICD-10 grace period would lead to inaccurate coding, improper payments, and potential medical billing fraud, opening the door to both intentional and unintentional coding errors. According to AHIMA, coverage determinations and validation of medical necessity of healthcare services also depend on codes submitted on claims and would be negatively impacted.
AHIMA counters Palmer’s assertion that the increase in the number of codes in ICD-10 versus ICD-9 will cause hardship for physicians by arguing that doctors and medical billers won’t need to learn every ICD-10 code in order to properly bill.
“Just as no healthcare provider uses every code in ICD-9-CM today, physicians and other providers will not use all the codes in ICD-10-CM,” states an AHIMA Frequently Asked Questions about ICD-10 document. “They will use a subset of codes based on their practice and patient population. The ICD-10-CM code set is like a dictionary that has thousands of words, but individuals use some words very commonly while other words are never used.”
Just when stakeholders thought the October 1 ICD-10 compliance deadline was a lock, a bill has been introduced in the U.S. House of Representatives that seeks to put the kibosh on the federal government’s plans to require the medical community to comply with the new code set.
According to Rep. Ted Poe (R-Tex.), sponsor of H.R. 2126, the Cutting Costly Codes Act of 2015, ICD-10 is a “burdensome bureaucratic system” that is financially strapping physician practices across the country which are suffering under the weight of the costs. The congressman cites studies which peg the costs of the code switchover at anywhere between $56,000 on the low end and $8 million on the high end.
Though an ICD-10 delay was not included in the recently-enacted Sustainable Growth Rate reform legislation, some physicians continue to call for yet another reprieve. However, Poe’s legislative objective is not to simply delay ICD-10 implementation but to outright prohibit the Secretary of the Department of Health and Human Services from replacing ICD-9 with ICD-10.
“The new ICD-10 codes will not make one patient healthier,” said Poe in a written statement. “What it will do is put an unnecessary strain on the medical community who should be focused on treating patients, not implementing a whole new bureaucratic language. Instead of hiring one more doctor or nurse to help patients, medical practices are having to spend tens of thousands just to hire a specialist who understands the new codes. Big government must get out of the way and let doctors do what they were trained to do—help people.”
The bill is co-sponsored by Rep. Mo Brooks (R-Ala.), Rep. Blake Farenthold (R-Tex.), Rep. Morgan Griffith (R-Va.), Rep. Tom Price (R-Ga.), Rep. David Roe (R-Tenn.), and Rep. Mike Rogers (R-Ala.). H.R. 2126 has been referred to the House Committees on Energy and Commerce and Ways and Means.
There have been a variety of ICD-10 coding concerns popping up across the healthcare sector, from physicians, nurses, billers, health IT specialists, and many more professionals. The Centers for Medicare & Medicaid Services (CMS) spoke with providers throughout the country and identified certain myths about the ICD-10 transition that many are worried about. Below are five facts that should dispel these myths and allay ICD-10 coding concerns.
- The ICD-10 Transition Deadline is Set
CMS encourages providers and payers to be prepared by October 1 for the ICD-10 transition because additional delays will not be occurring. Even though there were two delays beforehand in the past few years, ICD-10 coding concerns about another postponement are not valid, CMS explains. The deadline is set for October 1 and providers need to be ready.
The majority of healthcare providers, payers, and federal agencies have invested large funds in transitioning to ICD-10 coding. Any further delays will only lead to a rise in healthcare costs.
- Physicians and Healthcare Professionals Don’t Need to Use 68,000 Codes
Since physician practices do not currently use all 13,000 diagnosis codes applicable in the ICD-9 coding set, there will be no need to utilize every one of the 68,000 codes in ICD-10. These ICD-10 coding concerns are also based on a myth. Only a small subset of the total amount will be used.
- ICD-10 Codes Will Be Viewed in a Similar Fashion to ICD-9
Even though the ICD-10 coding set has more diagnosis codes, this does not make it harder to utilize. There is still an alphabetic index and digital tools that doctors and nurses can use to help select the right codes when treating patients.
- Codes Related to Outpatient and Office Processes are Staying the Same
Some ICD-10 coding concerns also address potential changes to outpatient and office procedure codes but these processes are staying the same after the ICD-10 transition deadline.
The movement toward ICD-10 for diagnostics and inpatient procedure coding doesn’t impact using CPT for outpatient and office coding. Physician practices will continue utilizing CPT.
- Medicare Fee-for-Service Providers Are Given the Chance to Test with CMS Before the ICD-10 Implementation
A physician practice or clearinghouse has the opportunity to conduct acknowledgement testing throughout any point in time with their Medicare Administrative Contractor (MAC) until October 1.
Acknowledgement testing will help providers ensure they are capable of sending claims with ICD-10 codes to CMS and relevant entities. In June 2015, a specific week dedicated to acknowledgement testing will be conducted by CMS in which providers and payers will have access to customer service and help desk support. Those interested in the acknowledgement testing week are encouraged to contact their Medicare Administrative Contractor for more information and details about testing plans.
These five facts about the ICD-10 transition was put together by CMS to put providers’ minds at ease. Those with other ICD-10 coding concerns should work with CMS to address any issues.