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Key Steps for ICD-10 Preparation before October 1 Deadline

By Vera Gruessner

- The ICD-10 compliance deadline will be here momentarily. Healthcare providers have little more than four months left before October 1, which means their ICD-10 preparation efforts must move forward quickly in order to be ready for the transition and avoid any reimbursement delays from the Centers for Medicare & Medicaid Services (CMS) as well as other health insurers.

ICD-10 Transition Deadline

To learn more about ICD-10 preparation and where providers should be heading, EHRIntelligence.com spoke with Pam Jodock, Senior Director of Health Business Solutions at HIMSS.

EHRIntelligence.com: “Where should a healthcare organization be in terms of ICD-10 preparations right now?”

Pam Jodock: “Ideally, they will have already gone through making sure all their systems are remediated, their documentation has been updated, and hopefully they’ve trained their physicians on documentation. The need for the more detailed elements of documentation on ICD-10, they’ll have trained their coding staff.”

“If they have 3rd party vendors, they’ll have received confirmation from their vendors that they’re ICD-10 ready and that their clearinghouse has tested with their payers. Larger organizations, especially, will have completed testing with CMS both on the end-to-end and acknowledgement testing. That’s the ideal situation.”

READ MORE: CMS to Update eCQM Value Sets for 2017 Reporting Period

“For those entities who are that far along the path, who have continued their implementation efforts despite the delay, they should be in pretty good shape. What they can be focusing on in the next few months before October 1 is looking at their reports. They need to make sure they’re ready to make the transition to ICD-10 and can account for any abnormalities that may occur because of the differences in coding.”

“The more detailed information might alter their numbers slightly on pay-for-performance. If they’re tracking patient activity related to diabetes, they may see those numbers go up slightly or go down slightly because of individuals they might not have captured under the ICD-9 coding. Those individuals may show up under ICD-10 because of additional detail. Looking at the reports and making they’re prepared for that [is important].”

EHRIntelligence.com: “What health IT solutions and services are working for providers with regard to ICD-10?”

Pam Jodock: “HIMSS is not in the position of endorsing specific vendors. We’ve been hearing a lot of positive reports from individual practices that are using vendors and clearinghouses for their solutions. We even saw in testimonies before Congress a few months ago where there was a solo practitioner who talked about the solutions in his office where the vendor essentially said, ‘On this day, you can code on ICD-9 and on this day, we may need to practice coding in ICD-10,’ and this was working.”

“We’re hearing a lot of end-to-end testing results are demonstrating that preparations organizations have made are working well for them. We’re hearing there is not a substantial increase in rejected claims under the testing area for ICD-10 than there were under the existing ICD-9. CMS had projected there might be one to two percent increase, but what we’re seeing is that it remains pretty stable. Regardless of the solution that’s being offered, they’re all working well.”

EHRIntelligence.com: “What testing plans should providers have for the months ahead especially providers that are behind in their ICD-10 preparation?”

Pam Jodock: “We do know that there are some solo and small practitioners out there who have not been able to dedicate as many resources to preparation because they’ve been hit with many other demands for their resources. They’re just now starting their preparation.”

“Testing with commercial carriers, you may have a very limited window left. A lot of commercial carriers will be ending their testing in June or July to focus on completing their transition. If there is still an opportunity to test with external partners, we would strongly encourage organizations to do so.”

“What we would recommend that they look at, is identify those ICD-9 codes they bill most frequently, identify the ICD-10 codes that they would bill for those procedures going forward, and also to look at those ICD-9 codes that generate the greatest percentage of their revenue and make sure they know what ICD-10 codes they will billing for those services going forward. They should create test scenarios using those codes and, if they can find a payer for end-to-end testing, use 25 to 30 scenarios. They can also use those same scenarios for acknowledgement testing with CMS all the way up until September 30.”

EHRIntelligence.com: “What is your viewpoint on Representative Diane Black’s ICD-10 bill?”

Pam Jodock: “This is a conversation we’ve had before. It would essentially require a period of dual coding. She has language in there about penalties. What I would note is that there is no penalty stage, technically, for ICD-10. If you’re not prepared to do ICD-10, if all you’re prepared to do is ICD-9, it may be viewed as a penalty in that there is no allowance for submitting ICD-9 claims.”

“The default penalty is that your claims will not be accepted. If you code in ICD-9 for services after October 1, your claim would automatically be rejected because it’s not coded properly. That is not considered a penalty phase. It’s just considered noncompliance.”

“She’s suggesting that we offer dual coding so that we can ease providers into the ICD-10 world. The challenge with that is that systems have been remediated across the industry based on date of service. For claims that are processed prior to October 1, there’s a whole different set of business rules and payment methodology that are applied to them. If you get to the fork in the road in the claims processing system and your date of service is before October 1, you go to the left. If your date of service is after October 1, you go to the right because the systems are not coded the same.”

“If you were to do dual coding, that would require an additional period of time for payers to again remediate their system and it would essentially result in a defacto delay.”

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