ICD-10 Compliance Deadline Is Oct. 1, 2015
IT HAS BEEN OVER 35 YEARS since the International Classification of Diseases, Ninth Revision, Clinical Modification, called ICD-9-CM was introduced to the medical profession. According to the Centers for Disease Control (CDC), the original intent of the code set was for the “classification of morbidity and mortality information for statistical purposes.” Although the original intent was epidemiological, through the passing of time, payer reimbursement policies were developed, and the codes are now closely linked to claims processing and provider reimbursement.
As we approach the Oct. 1, 2015 deadline set by the U.S. Department of Health and Human Services' (HHS) transition to ICD-10, the 10th revision of the International Classification of Diseases, it is of utmost importance to consider your clinic’s revenue cycle management. This step is often overlooked in most implementation processes; ACA encourages providers to set it as high priority. Just as ICD-9-CM far exceeded its predecessors in the number of codes provided, ICD-10-CM has been expanded to seven possible digits, allowing for thousands of new codes that permit greater specificity. It is important to know how ICD-9 codes affect your current revenue so that you can be proactive in your transition to ICD-10. We have outlined a few steps every doctor of chiropractic (DC) should consider:
• RUN AGING REPORTS
– Now is the time to fix all outstanding claim issues. Although claims with dates of service prior to Oct. 1, 2015 containing ICD-9 codes will be accepted, there may be additional delays, so you will want to submit all corrected claims now. The less you have to deal with ICD-9 claims after October 1, the better it will be for your clinic’s workflow process. If necessary, use ACA’s Appeal Template letters to assist your clinic in the appeal process found at www.acatoday.org/billing.
• SIGN UP FOR PAYER PORTALS
– Be sure that your ICD-10 project manager has access to the online portals for your top ten payers in order to receive the most current information regarding ICD-10 claims submission.
• REVIEW YOUR PAYER CONTRACTS AND REIMBURSEMENT POLICIES
– During the ICD-10 transition, a clinic cannot afford to have claims denied for reasons that could have been prevented if staff had known the payer’s clinical reimbursement guidelines or terms of the contract. The attitude “We always got paid for that in the past” or “I have been billing this way for 20 years” will only lead to lost revenue and unnecessary write-offs. Take time to find your topmost payers’ reimbursement policies for each and every procedure code rendered in your practice. Know for certain that your treatment plan, documentation and diagnoses meet the necessary payer requirements. It may help to create a folder and bookmark the online payer policies in your web browser or print this information and keep it in a binder labeled Payer Policies & Provider Contracts for easy access. You will want to check back often as policy updates including use of modifiers are updated quarterly by most payers.
• UPDATE ELECTRONIC HEALTH RECORD (EHR) TEMPLATES –
Confirm whether or not your software allows you to report laterality and site-specific conditions. Be aware that some EMR/EHR software actually ‘carry over’ the diagnoses to the next encounter when, actually, the condition has been resolved. A provider should list only diagnoses related to patient treatment for the current encounter. The same applies to paper chart records in which the provider may ‘carry over’ diagnoses from the initial date of service when it no longer applies to the current patient encounter.
• UPDATE FORMS –
Some clinics plan to continue using a Super-bill and therefore should be sure to include the clinic’s top 30 most commonly used ICD-10 codes, at a minimum. You should also check all payer preauthorization forms to be sure you have the most current form with adequate space for the ICD-10 codes. Finally, do not forget to update your software settings to allow you to report the correct indicator for Item 21 of the CMS Health Insurance Claim Form. The indicator can be found in the upper right area of the field, Item 21 (two dotted lines were added to create a one-byte space to report). The indicator is used to identify which version of the diagnosis code set is being reported. A “9” indicates the diagnosis codes are from the International Classification of Diseases, Ninth Revision (ICD-9) code set and “0” is for the International Classification of Diseases, 10th Revision (ICD-10). The use of the indicator will be necessary during the transition to ICD-10 and when reporting services that span the Oct. 1, 2015 implementation deadline. Because only one indicator can be used in this field, the diagnosis codes reported on the form must be all ICD-9 or all ICD-10.
• MONITOR TRAINING & STAFFING –
Make sure your team leader has received all the necessary training in order to code properly and submit accurate claims with the ICD-10 code set. It is important to keep in mind that productivity will be affected, and providers are encouraged to consider the workload of billing staff. They will need more time to carry out their job duties, and as a result you may have to delegate certain responsibilities to other staff. Keep in mind that close monitoring of claims processing will be very important for several months after the implementation deadline in order to avoid costly unnecessary denials.
• REVIEW YOUR CLINICAL DOCUMENTATION -
In the past, some doctors have lost out on reimbursement because of missing or illegible documentation. With ICD-10, documentation becomes even more crucial as doctors will be expected to support the specificity of ICD-10 with proper documentation. Once again, denials due to documentation are preventable if the provider takes the time to make the needed changes. CMS has provided ACA with ample evidence that providers’ current documentation is far from perfect. ICD-10 will only complicate matters as it requires laterality, site specificity, stage of care, type of injury, severity and external causes.
In order to bring your clinic in line with the payer’s documentation requirements, we encourage you to reach out now and request this information. Remember that good clinical documentation is not to be confused with greater volume of documentation. Take time to review your documentation to see if you are currently reporting patient health history, comorbidities, cause of injury and laterality. Ask yourself whether, for example, your documentation clearly supports a strain-of-muscle diagnosis when applicable rather than a sprain, since ICD-10 now separates these two conditions. By bringing your documentation up to the current standards outlined in payer contracts and by CMS (see CMS’ Clinical Documentation Improvement Webinar for more information at www.cms.gov/Medicare/Coding/ICD10/Downloads/DocumentationWebinar-Recording.pdf
), you will have very little tweaking to do to meet ICD-10 specificity requirements.
• PRACTICE –
Each day, code as many as possible, if not all, patient charts with both ICD-9 and ICD-10. The importance of dual coding is critical for successful ICD-10 transition. By practicing your coding ‘look up’ skills, you will have already familiarized yourself with the instructional notes for the different chapters and subcategories. You will also be familiar with coding options such as laterality and combination codes. By taking advantage of this time to dual-code, you will ensure coding accuracy from the start.
• TEST –
Now is the time you will want to review all testing results with vendors. Choose someone in your office to be accountable for reaching out to the software company, clearinghouse or insurance carrier to obtain this information and follow through with the necessary changes.
You may be wondering, “How will I ever ready myself and master coding with ICD-10 in time for the deadline?” To answer this question, it is best to consider Maxwell Maltz, a surgeon from the 1950s, who noticed a unique pattern among his patients and wrote, “It requires a minimum of about 21 days for an old mental image to dissolve and a new one to jell.” Maltz’s theory was soon mistakenly replaced with “It takes 21 days to form a new habit.” Many have forgotten that he said “a minimum of about 21 days,” and the result has often led people to complete frustration. With this in mind, know that it will take time to understand this new ICD-10 language. As you use the new code set, it will start to “jell,” and you will start to remember the ICD-10 code descriptions, instructional notes and documentation requirements. Therefore, as Dr. Maltz noted, it will more than likely take you more than 21 days to begin to feel comfortable with coding with ICD-10.
Take advantage of every opportunity to practice your coding skills and improve your documentation. Be determined to be well-prepared to go ‘live’ with ICD-10 coding on Oct. 1, 2015, by running your aging reports and cleaning up any reimbursement issues. Continue to look into the many ICD-10 resources ACA has available at www.acatoday.org/ICD10
. Being prepared is the surest way to reduce or eliminate unneeded hassles and delays in reimbursement.
Jill Foote is ACA’s insurance quality analyst III.