American Academy of Family Physicians
Tuesday Aug 05, 2014

It's official: You have another year to prepare for ICD-10

Last week, the secretary of Health and Human Services (HHS) issued a final rule designating Oct. 1, 2015, as the new compliance date for health care providers, health plans, and health care clearinghouses to transition to ICD-10.

That means that you and your practice have another year to prepare, and the Centers for Medicare & Medicaid Services (CMS) seems committed to doing what it can to help. CMS has implemented a comprehensive testing approach, including end-to-end testing in 2015, to help ensure providers are ready. Also, CMS has an extensive array of ICD-10 resources on its web site, including the Road to 10, a free online tool that enables small provider practices to create an ICD-10 action plan and jumpstart their transition. The AAFP also has ICD-10 resources on its web site, including a timeline to assist physicians in preparing the transition to ICD-10 and a tool to calculate how much it will cost to implement ICD-10 in your practice.

Not to be outdone, Family Practice Management has amassed a collection of articles on the topic.

Whether you seek resources from CMS, AAFP, FPM, or someone else, it is not too late and certainly not too early to get started in the transition process.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday May 06, 2014

Update on ICD-10 delay

A previous post noted that the Protecting Access to Medicare Act of 2014, which was enacted on April 1, 2014, said that the Secretary of Health and Human Services (HHS) may not adopt ICD-10 before Oct. 1, 2015. The law, however, did not limit when the Secretary could adopt ICD-10 beyond that date.

Accordingly, the Centers for Medicare & Medicaid Services (CMS) announced last week that the Secretary of HHS expects to release an interim final rule in the near future that will include a new compliance date that would require the use of ICD-10 beginning Oct. 1, 2015. The rule will also require Health Insurance Portability and Accountability Act covered entities to continue to use ICD-9 through Sept. 30, 2015.

CMS also announced that it has canceled the ICD-10 end-to-end testing that it otherwise planned to conduct during the week of July 21. CMS canceled the July testing due to the ICD-10 implementation delay and said additional opportunities for end-to-end testing will be available in 2015.

Meanwhile, the acknowledgment testing that occurred in March was apparently a success. CMS previously reported that from March 3 to March 7 they received approximately 127,000 ICD-10 acknowledgment test claims, representing about 5 percent of those who submit claims to Medicare. CMS and its contractors encountered no systems problems associated with those test claims. CMS had originally planned to offer another week of acknowledgment testing this month; there is no word yet on whether it will still do so or postpone that to 2015 as well.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Wednesday Apr 09, 2014

SGR, ICD-10 not the only targets of adopted legislation

Last week's SGR legislation didn't just push back Medicare cuts and delay ICD-10 implementation.

A new blog post by Betsy Nicoletti notes that the 123-page bill passed by Congress and signed into law by President Obama also requires additional reporting for lab test reimbursements and creates greater scrutiny of CT scans.

Read the blog here:

Tuesday Apr 08, 2014

Another patch and more time to prepare for ICD-10

Following up last week's post, the Senate approved and the president signed a House bill that prevents steep cuts to Medicare physician payments from going into effect for one year. The bill (now law) also delays the conversion to ICD-10 diagnostic and procedure codes for at least one year.

The measure calls for a 0.5 percent increase in physician payments through Dec. 31, 2014, and no change from Jan. 1 through March 31, 2015. That means is that it will be another year before you have to worry about a potential cut in the Medicare physician payment rate. It also means that Congress has additional time to pass a permanent repeal of the Sustainable Growth Rate that has led to the current predicament. Such action in advance of the mid-term elections seems unlikely, however, given the current lack of agreement on how to pay for repeal.

On the plus side, the delay in ICD-10 does give physicians more time to prepare for that change, which will now occur on Oct. 1, 2015 (or later). Until then, everyone will continue to use ICD-9 codes. That said, you shouldn't use the delay in implementation as an excuse to delay preparation. Physicians, payers, and other users of ICD-10 should continue to move forward with preparation wherever they are in the process, and AAFP has resources to help its members do just that.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday Mar 04, 2014

Medicare plans additional testing for ICD-10

If you're not participating in this week's test of the ICD-10 coding change, you'll get a second chance soon.

Last week, the Centers for Medicare & Medicaid Services (CMS) announced that it would add a second week of acknowledgement testing for physicians and others who submit Medicare claims. It also provided more details about end-to-end testing with Medicare.

The announcement came in the form of an article revision on the Medicare Learning Network (MLN). According to the revision, CMS plans to offer a second week of acknowledgement testing in early May 2014.

The revised article also states that CMS will offer end-to-end ICD-10 testing in late July 2014 to a small sample group of providers. End-to-end testing tracks a claim from initial connectivity and claim submittal all the way through remittance advice (RA), denials, and refund requests. CMS’s goals for this test are to demonstrate that:

• Providers or submitters are able to successfully submit claims containing ICD-10 codes to the Medicare fee-for-service claims systems;

• CMS software changes made to support ICD-10 result in appropriately adjudicated claims (based on the pricing data used for testing purposes); and

• Accurate RAs are produced.

CMS will select more than 500 volunteer submitters for the project, choosing a broad cross-section of providers, suppliers, and other submitters and claims types. CMS will provide information on volunteering later this month and disseminate additional details about the test in a separate MLN Matters article.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday Jul 09, 2013

CMS 1500 claim form gets an update

The National Uniform Claim Committee has updated the CMS-1500 insurance claim form to accommodate the new ICD-10 codes and current standard for electronic health care transactions.

Known as "version 02/12" and approved by both the Centers for Medicare & Medicaid Services (CMS) and the Office of Management and Budget, the updated claim form includes revisions designed to improve the accuracy of data reported. 

Two changes of note:

• Physicians can identify in Item 21 whether they are using ICD-9 or ICD-10, which will come in handy during the transition to the new codes in October 2014. As noted in a previous post, it depends on the actual date of service whether you use ICD-9 or ICD-10 on claims submitted after Oct. 1, 2014.

• The diagnosis field in Item 21 will allow up to 12 codes. The current form (version 08/05) is limited to four.

Other revisions will also help with accuracy. For instance, you will now be able to identify in Item 17 the role of the provider as “Ordering,” “Referring,” or “Supervising."

The start date for using the revised form has not yet been announced. However, Medicare anticipates implementing the revised claim form as follows:

• Jan. 6, 2014 – Medicare begins receiving and processing paper claims submitted on the revised form.

• Jan. 6, 2014, through March 31, 2014 – Providers can use either the current form or the revised one.

• April 1, 2014 – Only the revised form can be used.  

These dates are tentative and subject to change. CMS will provide more information as it is available. Also, CMS is updating the Medicare Claims Processing Internet Only Manual to instruct contractors and physicians regarding how to complete the revised form online and will post this information on the CMS website when it is available.

If you still submit paper claims, you would be wise not to purchase large quantities of the current form. If your practice submits electronic claims, you should speak to your software vendor to determine how and when your practice management system will be updated to accommodate the revised form.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday Jun 13, 2013

Practices report slow transition to ICD-10

With less than a year and a half until medical practices must begin using ICD-10, many are far behind in their preparations.

In a new report released Thursday, the Medical Group Management Association (MGMA) said 55.4 percent of the more than 1,200 practices surveyed indicated that they had yet to start implementing ICD-10, which goes into effect Oct. 1, 2014.

Less than 5 percent reported that they had either completed implementation or had made significant progress.

Many respondents blamed their tardiness on a lack of action by their claims clearinghouses, electronic health record (EHR) vendors, and their practice management system vendors. For instance, while more than 83 percent of practices said their practice management systems will need to be upgraded or replaced to work with ICD-10, 52.5 percent said they haven't heard from their vendor when that upgrade or replacement will be available.

Also, at least 42 percent said their practice will have to pay for the work at an average cost of $10,190 per full-time equivalent (FTE) physician.

On the EHR side, 71 percent of respondents said they'll need an upgrade or replacement, but 49.7 percent haven't heard from their vendors. The average cost for doing the work is expected to be $9,979 per FTE.

Despite the lack of plans, less than 14 percent of practices said they have no confidence that their practice management and EHR vendors would be ready by Oct. 1, 2014.

The no-confidence level went up slightly to almost 18 percent for claims clearinghouse partners but surged to more than 38 percent for major health plans.

The more than 1,200 practices surveyed included more than 55,000 physicians.

Thursday May 16, 2013

Date of service decides whether you use ICD-9 or ICD-10

With the Oct. 1, 2014, deadline for implementing ICD-10 coding approaching, you may be wondering how you will treat a claim that you submit in October 2014 for a service that your practice provided in September 2014? Do you use ICD-10 because the claim is filed after the implementation deadline, or do you use ICD-9 because the service was provided before the deadline?

The short answer is that the date of service determines which code set you use. Thus, even if you submit your claim on or after the ICD-10 deadline, if the date of service was before Oct. 1, 2014, you will use ICD-9 to code the diagnosis. Conversely, for dates of service on or after Oct. 1, 2014, you will use ICD-10. That means you need to make sure that your systems, third-party vendors, billing services, and clearinghouses can handle both ICD-9 and ICD-10 codes for claims filed in the months following Oct. 1, 2014.

While some trading partners may allow that ICD-9 and ICD-10 codes be submitted on the same claim when dates of service span the compliance date, not all of them will. This may mean splitting services into two claims: one claim with ICD-9 diagnosis codes for services provided before Oct. 1, 2014, and another claim with ICD-10 diagnosis codes for services provided on or after Oct. 1, 2014. Check your trading partner agreements.

For additional help, visit the American Academy of Family Physicians website for tools and articles to assist your practice with the preparation and change to this new system. You can also find news and resources on the Centers for Medicare & Medicaid Services' (CMS) ICD-10 website, which also includes the ICD-10 continuing medical education modules developed by CMS in partnership with Medscape.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Wednesday Feb 20, 2013

CMS refuses to halt ICD-10-CM implementation

The Centers for Medicare & Medicaid Services (CMS) has denied a request from more than 80 state and national physician organizations, including the American Academy of Family Physicians (AAFP), to halt implementation of ICD-10-CM.

The Dec. 20, 2012, letter to CMS Acting Administrator Marilyn Tavenner requesting the delay argued that the new set of outpatient diagnosis coding would create additional, unnecessary burdens for America's physicians at a time when many are overwhelmed with other health care system demands and changes.

On Feb. 6, 2013, Tavenner declined the request and said that CMS will move forward with implementing ICD-10 on Oct. 1, 2014. She noted that this already represented a year’s extension beyond the original implementation date of Oct. 1, 2013. Tavenner also said that halting implementation at this point "would be costly, burdensome, and would eliminate the impending benefits" of the investments that many in the industry have already made with respect to implementation.

So, for now, ICD-10 proponents have carried the day, and everyone needs to look for strategies to ease implementation. If you have not already developed an implementation plan, here are some resources to help you.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday Dec 20, 2012

Begin the Beguine, or loosening up for some ICD-10 dance steps

Is it necessary to love big band jazz in order to properly understand the new ICD-10 coding? No, but it would certainly help with the fancy footwork involved.

The "Getting Paid" blog will address in coming posts what major changes to look for in specific chapters of ICD-10. In the meantime, we'll look at the new coding system's Conventions and Guidelines. These are all available for download on the CDC website.

First off, ICD-10-CM has 21 chapters, up from 17 in ICD-9-CM as codes for certain conditions either break off to form their own sections or get roped in with others. The V and E codes, which detail supplemental factors influencing a patient's health and the external causes of injury, will be incorporated in the main classification under ICD-10-CM. Meanwhile, diseases and conditions of the eyes and ears will get their own chapter, separated from their current home in the nervous system section.

Injuries will now be classified by site, and then by type. Postoperative complications have been moved to procedure-specific body system chapters. Also, some codes have been combined. For example, coding for type 1 diabetes mellitus with diabetic neuropathy will no longer require two codes (one for the diabetes and one for the neurological manifestation) but a single code of E10.21.

In ICD-10-CM, as with ICD-9-CM, notes and parenthetical instructions are still present. The manual will still use "code first" and "use additional code," as well as "includes" and "excludes" notes. Also remaining are "not otherwise specified (NOS)" and "not elsewhere classified (NEC)." The term "and" is interpreted to mean "and/or" when it appears in a code title within the tabular list. The word "with" is interpreted to mean "associated with" or "due to" when appearing in a code title.

On the other hand, certain symbols, such as the lozenge, section mark, and braces are disappearing. Instead, ICD-10 will use dashes at the end of a code to signal that it requires additional characters. One example is M84.47-, which could represent any fracture to an ankle, foot, or toe (M84.472 is a fractured left ankle). ICD-10 does two types of "exclude" notes to modify some codes. "Excludes 1" lists condition codes that can't be used at the same time as the primary code. "Excludes 2" notes conditions that are not part of the primary code but that a patient could present at the the same time, meaning that both codes being used together are acceptable.

The alphabetic index of ICD-10 is divided into two parts – the index to diseases and injuries and the index to external causes – while the type and format layout uses the same mechanics as ICD-9.  Morphology codes are no longer listed in the alphabetic index, and they no longer have a separate appendix in ICD-10.

As I said earlier, the tabular list is divided into 21 chapters. Some of the reclassifications of diseases to different chapters were done for better alignment.  Each chapter is then divided into subchapters that contain three characters and are similar to the ICD-9 foundations.  Each chapter in ICD-10 begins with a summary of the blocks and an overview of the categories within the chapter. Some of the subchapters are divided into even more specific subchapters. 

The takeaway? With all of the changes ahead with ICD-10, getting up to speed will likely be less of a graceful waltz and more of a frantic jitterbug. But the AAFP is here to help you get through it.

–Debra Seyfried, MBA, CMPE, CPC, Coding and Compliance Strategist for the American Academy of Family Physicians

Thursday Nov 08, 2012

Who is your ICD-10 champion?

The time has come to begin planning for implementation of ICD-10 diagnosis codes. The implementation deadline is Oct. 1, 2014. Think of ICD-10 like a favorite food dish, best served in smaller portions over time. You should begin by identifying a capable leader who can oversee an ICD-10 project team. This should be someone with an understanding of ICD-10 who is able to communicate clearly about the reason for and implications of the change. With the team leader in place, an implementation team can be appointed. Be sure to have a good representation from both the clinical and business sides of your practice. ICD-10 will affect everyone in your office, and having input from staff with varying job duties will save headaches in the long term.

Once you have your team in place, begin delegating different areas of focus to your team members. These areas may include medical records, billing, front desk check-in, check-out, procedure scheduling, and ancillary services. Ask team members where they see, speak, hear, or write ICD-9 codes. Challenge them to assess these areas and determine if there is a policy or procedure that will need updating to include ICD-10 nomenclature. You should create a master list that contains the names and the positions of those who are affected and describes the impact ICD-10 will have on them. Keep this list on display to build awareness and prepare staff for future discussions about their involvement in the implementation of ICD-10. It will also be a helpful resource as you move forward in the implementation process. Next steps will involve analysis, revisions, restructuring, and training. Establish a regular meeting schedule for the next two years to help keep your group on track.

For more information and a timeline for ICD-10 implementation, see the American Academy of Family Physicians ICD-10 website.

–Debra Seyfried, MBA, CMPE, CPC, Coding and Compliance Strategist for the American Academy of Family Physicians

Monday Aug 27, 2012

It's official: ICD-10 delayed to Oct. 1, 2014

Department of Health and Human Services (HHS) Secretary Kathleen Sebelius made official a one-year delay in the implementation deadline for the ICD-10 diagnosis code set when she announced last Friday a final rule that sets the new compliance date at Oct. 1, 2014.  The delay, which was the subject of a proposed rule last April, is part of a final rule that will establish a unique health plan identifier, which HHS promises will "help cut red tape in the health care system." More to come on the HPID, as it's referred to. In the meantime, check out FPM's ongoing series of articles on ICD-10

Monday Apr 23, 2012

ICD-10 delay proposed, but that's not all

By now you have likely heard the Office of the Secretary of the Department of Health and Human Services (HHS) has formally proposed delaying the transition date for ICD-10-CM to Oct. 1, 2014. Good news for the practices that have not started or do not know when they will start preparing for ICD-10 (76 percent, according to today's reading of FPM's Reader Poll; vote and view the latest results in the left column of FPM's home page). You have an added year to get your plans in order and get caught up in preparing for this transition.

But this is not the only portion of this proposed rule that affects your practice. This rule also adds the implementation date for national unique health plan identifiers (HPID). By Oct. 1, 2014, all large health plans (i.e., payers) must apply for an HPID, just as physicians have applied for their national provider identifier (NPI). In addition, claims administrators, clearinghouses, and other entities involved in the claims process wil have the opportunity to adopt a national Other Entity Identifier (OEID). While this is good news in that it should eliminate some of the issues that occur with claims transmissions not routing to the correct claims administrators or payers, it will come with some costs to your practice.

By Oct. 1, 2014, your billing system must be equipped to include these numbers on your claims. Small health plans have until Oct. 1, 2015, to comply, which complicates matters because you may need to send the HPID on most but not all claims. If your software vendor or clearinghouse didn't fare well in the transition to the HIPAA (Health Insurance Portability and Accountability Act) 5010 electronic transactions standards, now would be a good time to discuss with them when they will start planning and working to achieve compliance with the HPID. The timeline provided in the proposed rule indicates that your systems should be ready to send test transmissions of claims with the HPID by April 1, 2013.

If you have comments on any of these proposals, the rule includes a comment period of 30 days from the date of publication in the Federal Register. Comments should include file code CMS-0040-P and may be submitted electronically on or in writing to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-0040-P, P.O. Box 8013, Baltimore, MD 21244-8013.

While you'll have an extra year to get ready for ICD-10, there is another sizable task on the to-do list – to prepare your claims systems to submit the HPIDs. I guess it is true that what one hand giveth, the other taketh away.


Tuesday Apr 17, 2012

ICD-10: The gift of time

In February, I posted that the U.S. Department of Health and Human Services (HHS) had signaled its intent to delay implementation of International Classification of Diseases, 10th Edition (ICD-10), which was scheduled to happen on Oct. 1, 2013. Now HHS made it almost official.

HHS Secretary Kathleen Sebelius announced a proposed rule that would delay the compliance date for ICD-10 from Oct. 1, 2013 to Oct. 1, 2014. The proposed rule is subject to a 30-day comment period before HHS finalizes it and makes the proposed delay completely official. 

As Cindy Hughes has noted in her most recent article in Family Practice Management, "While the delay may give you more time to prepare, it most certainly does not mean that you can postpone this work; it just means that if you start now, you might actually be ready by the new deadline." Cindy's article provides some great information in this regard, and you can find more information and resources on the American Academy of Family Physicians website.

So, HHS has provided the gift of another 365 days to prepare for implementation of ICD-10. Physicians and others would do wisely to use this gift to their advantage in getting ready. It seems unlikely that HHS will be this generous again in advance of the new deadline.

Thursday Feb 16, 2012

ICD-10 delay may be in the works

With 5010 implementation effective Jan. 1, 2012, the next major hurdle facing physicians and the rest of the health care system is implementation of International Classification of Diseases, 10th Edition  (ICD-10). Currently, that is slated to happen on Oct. 1, 2013.

Or is it? This week, officials at the Centers for Medicare and Medicaid Services (CMS) and Health and Human Services (HHS) announced that a delay in implementation may be forthcoming. First, on Tuesday, acting CMS Administrator Marilyn Tavenner told reporters that the CMS will "re-examine the timeframe" for ICD-10 implementation through a rulemaking process. She did not say when that rulemaking process will begin, and she did not actually say that implementation will be delayed.

Then, on Wednesday, HHS Secretary Kathleen G. Sebelius announced that HHS will initiate a process to postpone the date by which certain health care entities have to comply with ICD-10. In a press release, the agency stated, "HHS will announce a new compliance date moving forward."

So, it appears that a delay in implementation is in the works. However, how much of a delay and to whom it will apply remain unknown. Pending answers to those questions in the form of a posting in the Federal Register, physician practices are probably best advised to continue preparing for implementation on Oct. 1, 2013. Like the Boy Scouts, it is better to be prepared, lest the anticipated delay does not come to fruition.

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