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Coding & Billing: The Countdown to ICD-10
Be ready for the October deadline with these 6 steps.
Cristina Bentin
Publish Date: June 4, 2015   |  Tags:   Financial Management
ICD-10 READY FOR ICD-10? All claims submitted to Medicare after Oct. 1 must use the new codes or they won't be accepted.

After 3 delays, it looks like the long-awaited ICD-10 coding system will finally go live in October. There's more to ICD-10 than just learning a new code set and upgrading your software (see "5 Fast Facts About ICD-10"). The switch to new diagnostic and procedural codes will affect every aspect of your facility. You'll suffer through added expenses and workflow disruptions, but in the end you'll benefit from greater coding accuracy and specificity. Here are 6 tips for a smooth transition.

Contact your vendors
Reach out now to your software, EHR, EMR and patient accounting system vendors. Either begin the process for updating your online coding system with built-in ICD-10 functionality or confirm when the new system update for ICD-10 will be completed. Review any contracts to verify these timelines, as well as see what support is available.

You also want answers to these questions:

  • Will there be training for the updated system?
  • Will there be a fee for an upgrade from the current system?
  • When will the system upgrade be completed and available?
  • Will the updated system be able to maintain and allow for review of both ICD-9 and ICD-10 code sets by clinical concept?

Additionally, work with clearinghouse and billing vendors to test the system ahead of time. Test claims submissions in advance with all payors — no exceptions. Coordinate with your payors, clearinghouses and billing services on when to send these transmissions to avoid confusion. You also want to ask them whether your system will be able to support and transmit both ICD-9 and ICD-10 claims since you'll still need to be able to work with ICD-9-coded claims for older dates of service, such as rebills, after Oct. 1.

Examine payor contracts and reimbursement policies
Current payor contracts and payment policies may contain language that's no longer applicable under ICD-10. For example, conditions deemed medically necessary under ICD-9 may not translate to medically necessary conditions in ICD-10. To avoid this, review your payor reporting, documentation and provider requirements, and compare these with applicable ICD-10 draft policies. CMS can provide your facility with state-specific ICD-10 draft policies for your common procedures and Medicare population. Review these policies and directives now to ensure continued medical necessity coverage.

Additionally, check that payor contracts address what happens if the payor breaches its timely payment requirements. Since ICD-10 may cause system glitches, ask each payor for its written contingency plan should there be reimbursement delays. Finally, you also want to analyze your payor mix, volume and percent of revenue. A disruption in payment by a single payer can prove disastrous if it's responsible for 25% of your facility's volume and revenue.

Review current forms
ICD-10 demands a higher level of specificity than you and your staff may be used to. Before October, review all applicable forms that may be impacted — including ABNs, history & physical forms, HIPAA disclosure/restriction forms, EHR/EMR templates and anesthesia/nurse record forms — to ensure they're formatted correctly for the new system.

On The Web

For more information about ICD-10, visit the CMS website at cms.gov/ICD10.

Have a budget Plan B
While your 2015 budget has long been established, make sure you have a Plan B budget in place to account for any disruption in payment. One good option is to have several months' cash reserves or access to cash through a loan or line of credit. Although you can't control whether your payors will be ready, you can prepare for reimbursement delays by expanding your working capital line of credit. Make sure you communicate with banks early before you need these funds.

Assess staffing needs
Think in terms of a worst-case scenario if ICD-10 slows down your staff's productivity. Consider outsourcing coding services to address backlogs, which would give your staff more time to learn and practice ICD-10. If you're considering using a third party, now's the time to research, secure proposals and verify availability. Remember, when demand rises, so does the price tag. You could also assign ICD-9 experienced staff only to ICD-9 claims, and ICD-10 experienced staff to ICD-10 claims only until older dates of service are resolved.

Begin dual coding
Perhaps the best way to smooth the transition is to simultaneously code ICD-9 and ICD-10 codes leading up to the deadline. While payors can't adjudicate ICD-10 claims until Oct. 1, performing dual coding lets your staff catch problems early and become more familiar and comfortable with the new system.

You can decide to dual code all or only a portion of cases based on your current coding volume and other responsibilities. If your staff dual codes only a portion of cases, be sure to periodically increase that amount as Oct. 1 approaches. Expect your coder's productivity to lag: If she was coding 7 to 10 multi-specialty charts per hour, she might only be able to handle 3 to 6 while she gets up to speed.

Dual coding helps identify potential documentation problems. While some ICD-9 codes are already mapped to an ICD-10 code, your coder can take note of codes listed as "unspecified" or "not otherwise specified" and spot any trends that may lead to a documentation deficiency. If you identify a documentation deficiency, alert your doctors right away. Even though you may have warned surgeons about documentation issues previously, they could think that their current documentation is okay if you don't tell them otherwise.

No more false starts?
Who can say for sure that ICD-10 is entirely safe from further delay? Yes, Congress could once again postpone the code set conversion. But you should keep moving toward the Oct. 1 compliance deadline knowing that this time, it might just happen.

5 Fast Facts About ICD-10

  1. ICD-10 has about 69,000 codes and will replace the aging 14,000 ICD-9 diagnosis codes that doctors, hospitals and surgery centers currently use to bill insurers.
  2. With their high level of diagnostic specificity, the new codes will make it easier to describe advanced surgeries and procedures that generally command higher reimbursement rates.
  3. ICD-10 offers greater detail and increased ability to accommodate new technologies and procedures. The codes have the potential to provide better data for evaluating and improving the quality of patient care. For example, data captured by the code sets could be used to better understand complications, design clinically robust algorithms and track care outcomes.
  4. ICD-10's finer detail and cleaner logic may lead to fewer coding errors in the long term.
  5. ICD-9 codes were not developed for reimbursement purposes; that use came after their implementation. ICD-10 offers more rational systems upon which to build payment systems.