Electronic Health Records

Adoption & Implementation News

Why You Should Support the Safe Harbor ICD-10 Conversion Bill

By Vera Gruessner

- The ICD-10 conversion brings with it many complications and physician groups across the country are looking to avoid putting additional time and monetary strain among providers from implementing the new coding set. In that attempt, Representative Diane Black (R-TN-6) issued bill H.R.2247 called Increasing Clarity for Doctors by Transitioning Effectively Now Act (ICD-TEN Act).

ICD-10 Coding Implementation

Instead of seeking to delay the ICD-10 conversion any further or put an end to the new coding system altogether as prior proposed bills have suggested, it mandates an ICD-10 transition period – or a “safe harbor” period – before which the Department of Health and Human Services (HHS) would perform end-to-end testing among all providers to determine whether the fee-for-service reimbursement system is working properly and complies with ICD-10 codes.

Dr. Will Harvey, a practicing rheumatologist and Government Affairs Committee Chair for the American College of Rheumatology, is a strong supporter of bill H.R.2247 and spoke with EHRIntelligence.com about why this legislation is so important.

When asked his reasons for supporting the ICD-10 bill, Harvey answered, “There are two reasons. One, in particular in the specialty of rheumatology but certainly true in all of medicine, a large number of our practices are small solo or small group practices with many in rural or other under-served areas, which leads us to be concerned about our ability to adequately test our systems. The reason is the end-to-end testing that’s being performed by CMS right now is restricted to around 2,500 testers who are selected because of their prototypical nature.”

“If these 2,500 people do okay with testing, then there will be enough practices like those 2,500 out there that will feel comfortable about their ability to successfully use the system,” Harvey continued. “The thing that concerns us about this is that if there are 10 electronic health records, 10 billing systems, 10 clearinghouses, and 10 revenue management software vendors out there, then that leads to 10,000 different permutations of different software types that one would use to transmit their bill from the practice to CMS and back. And, of course, there are many more than 10 of each of those things.”

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

“Our concern is that the 2,500 prototypical testers is not enough to reassure providers – particularly ones in rural or small areas – that their systems will work because often they have unique software products that may not be adequately tested,” Harvey mentioned.

When discussing his second reason for supporting Representative Diane Black’s ICD-10 bill, Harvey explained, “The concern related to the safe harbor period or the implementation period of 18 months is that there’s a lot of learning that will have to happen around ICD-10 after October 1. This is due to the combination of people being inadequately prepared and things like payer edits and different ways in which the codes will be used that we don’t even understand yet.”

“One of our big concerns is that the added specificity contained within ICD-10 will be used to deny or modify payment or even more egregiously be used to assess waste or fraud. We are trying to help people understand that – because of the complexity of the system – minor mistakes in sub-codes are not fraud, they’re just mistakes. Because the learning curve will continue after October 1, we think it’s very reasonable to allow providers this implementation period where they will not be penalized or denied payment on the basis of a simple mistake in a sub-code.”

“We’re not suggesting that any code be accepted,” Harvey further explained his points. “We’re just suggesting that sub-codes are the ones that are the least important when determining payment. They’re more important for epidemiological and public health purposes rather than payment.”

When asked which providers might be negatively affected by the ICD-10 conversion, Harvey replied, “From a technical perspective, it’s always more difficult for small groups or solo practitioners or people who are working in traditionally underserved areas because they work on much, much smaller margins to operate their business.”

“They often run on margins of a couple percent. Even a couple percent increase in rates of claims denial will threaten the viability of those practices and ultimately affect patient access,” Harvey stated. “From a practical perspective in who will have the most difficulty handling the increase in the number and complexity of codes based on their specialty, cardiology is one affected and oncology is another. Orthopedics perhaps has the greatest increase in the number of codes. Emergency physicians are affected [by the ICD-10 conversion] because of the large amount of specificity around accidents and injuries of various types. The number of codes that rheumatoloigists will consider for rheumatoid arthritis goes from one to 246.”

With regard to whether the ICD-1o conversion could severely impact reimbursement among a large number of providers, Harvey stated, “Unfortunately, I’m not sure [whether this would occur]. That’s part of why we would like more comprehensive testing before October 1 because it will give us that answer.”

“Our software that we have right now does not support dual coding,” Harvey continued. “We can’t run any analytics to find out whether our providers are adequately coding at an ICD-10 level. We will only be able to do that after October 1 when we turn on the ICD-10 functionality inherent in our system.”

“If we can’t start doing analytics until after October 1, how can we possibly answer how much we’ll be impacted financially, but also how can we train people if they can’t on a day-to-day basis use the new system in their daily practice? This will all happen to a large extent after October 1, which is why we’re pushing so strongly for the safe harbor period.”

When asked what safeguards under the proposed legislation are the most important, Harvey replied, “I think the most important for America’s small and solo practitioners is the testing piece because they’re at high risk. For everyone else and for those people, I think the safe harbor piece is the most important. It’s well known among the health IT industry that we have accuracy problems already with ICD-9 and that problem will only get worse during the implementation with ICD-10. We feel that it’s common sense to let everyone learn on the job for 18 months before we’re held to strict accountability for the specificity held in the coding set.”

Harvey also gave tips to healthcare providers to mitigate risk when it comes to the ICD-10 conversion by the October 1 deadline.

“Even if you cannot participate in the CMS-sponsored end-to-end testing, I hope every provider is testing their own internal systems or getting documentation from their various vendors that their systems will be ready on time,” he stated. “I think another point is to get providers and their staff trained on the new code set so that we’re minimizing the learning curve that has to happen on October 1.”

Dr. Will Harvey concluded by mentioning how it would benefit providers if the Centers for Medicare & Medicaid Services (CMS) was more transparent with regard to their contingency plans for the ICD-10 conversion.

“They [CMS] haven’t released [the contingency plans] publicly,” Harvey concluded. “One thing we would very much like is for them to put out their contingency plans so that we can review them and see whether they’re adequate. We generally don’t feel as though legislation should be necessary to deal with these issues, but in part it’s because of CMS’ lack of transparency in this regard that we feel compelled to support this legislation.”

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