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.
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
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
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
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
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.
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 http://www.regulations.gov 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.
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.
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.
Get them while they're hot! And then, enjoy the freeze.
With time to spare, the editors of FPM magazine have provided not only an article describing the ICD-9 code changes that take place on Oct. 1, 2010, but an updated array of ICD-9 tools to help you bill the correct diagnosis codes for dates of service through Oct. 1, 2011.
The September/October issue of FPM includes the article as well as the FPM short list of ICD-9 codes for family medicine. The short list and a long list can be downloaded in PDF or Excel format from the ICD-9 resources page in the FPM Toolbox. The FPM superbill and a searchable ICD-9 database for PDA users have also been updated and can be downloaded there as well. Be sure to share these valuable resources with your staff.
We also have good news about future code updates. The ICD-9-CM Coordination and Maintenance Committee will implement a partial freeze of the ICD-9 and ICD-10 codes prior to the implementation of ICD-10 on Oct. 1, 2013.
The partial freeze will be implemented as follows:
- The last regular, annual updates to both ICD-9 and ICD-10 code sets will be made
on Oct. 1, 2011.
- On Oct. 1, 2012, there will be only limited code updates to both the ICD-9 and ICD-10 code sets to capture new technologies and diseases.
- On Oct. 1, 2013, there will be only limited code updates to ICD-10 code sets to capture new technologies and diagnoses. There will be no updates to ICD-9, as it will no longer be used for reporting.
- On Oct. 1, 2014, regular updates to ICD-10 will begin.
The partial freeze should allow you, your staff, software vendors and payers to focus on ICD-10 training and implementation of ICD-10 codes for the next three years without having to also keep up with significant changes to either the ICD-9 or ICD-10 code sets.
During this time, FPM and the AAFP will continue to offer information and resources to help you through the ICD-10 training and transition and keep you up-to-date on any code changes due to new diseases effected during the freeze.
CMS offers free ICD-10 teleconference on Sept. 13
The AAFP has information and resources for learning about and planning for transition to HIPAA 5010 electronic transaction standards and ICD-10 diagnosis codes, but we thought it might also be helpful to alert you to the free resources that the Centers for Medicare & Medicaid Services (CMS) is providing. Among these resources are conference calls to provide basic information and answer questions you or your coding and billing staff may have.
CMS will soon host a national provider conference call on "ICD-10 Implementation in a 5010 Environment." Subject matter experts will review basic information on both ICD-10 and 5010 and explain how they are interrelated. A question and answer session will follow the presentations.
When: Monday, Sept. 13, 2010;
Time: 12:00 p.m. – 1:30 p.m. ET;
Target Audience: Medical coders, physician office staff, provider billing staff, health records staff, vendors, educators, system maintainers and all Medicare fee-for-service (FFS) providers.
The following topics will be discussed:
• ICD-10 implementation for services provided on and after Oct. 1, 2013;
• Differences between ICD-10 and ICD-9-CM codes;
• Tools for converting codes – General Equivalence Mappings (GEMs);
• Proposal to freeze ICD-9-CM and ICD-10 code updates except for new technologies and diseases;
• Compliance dates and timelines (no contingencies);
• 5010 before and after ICD-10 implementation;
• Readiness review for implementing HIPAA version 5010 and D.0;
• What you need to be doing to prepare;
• Medicare fee-for-service activities update.
For more information and to register for this informative session, please go to http://www.cms.gov/ICD10/02c_CMS_Sponsored_Calls.asp#TopOfPage on the CMS web site. Registration will close at 12:00 p.m. ET on Sept. 10, 2010, or when available space has been filled. No exceptions will be made. CMS asks that you please register early.
If your practice has not begun preparations for these big changes, this may be an invitation you don't want to miss.
Free ICD-10 teleconference June 15th
The Centers for Medicare & Medicaid Services (CMS) is working to bring together physicians, payers and electronic systems/service vendors to make the dreaded transition to the ICD-10 diagnosis code set smoother than past HIPAA-required changes. A consistent message in ICD-10 communications from CMS: There will be no delay in implementation. You must be ready and able to bill with ICD-10 codes on Oct. 1, 2013.
To effect this smooth transition, CMS has participated in educational summits and recently hosted a conference for billing services, software vendors and clearinghouses to discuss planning, testing and resources that can make implementing ICD-10 easier.
But what about physicians, who may ultimately suffer unpaid claims if the transition to the new codes doesn't go smoothly? You have not been forgotten. CMS will soon host a national provider conference call on "ICD-10 Implementation in a 5010 Environment" to provide you and your staff with information to use in planning for this change. Here are the details, should you or someone from your office wish to participate:
When: Tues., June 15, 2010
Time: 12 p.m. – 2 p.m. ET
Target Audience: Medical coders, physician office staff, provider billing staff, health records staff, vendors, educators, system maintainers and all Medicare fee-for-service (FFS) providers
You must register for the call. Registration will close at 12 p.m. ET on June 14, 2010, or when available space has been filled. No exceptions will be made, so please be sure to register prior to this time. You only need to register once per phone line, no matter how many individuals from your practice will be listening to the call.
To register, go to: http://www.eventsvc.com/palmettogba/061510
Fill in all required data.
Verify that your time zone is displayed correctly in the drop down box.
You will be taken to the "Thank you for registering" page and will receive a confirmation email shortly thereafter. NOTE: Please print and save the registration page, in the event that your server blocks the confirmation emails. If you do not receive the confirmation email, please check your spam/junk mail filter as it may have been directed there.
If assistance for hearing impaired services is needed, the request must be sent to "firstname.lastname@example.org" no later than 3 business day before the event.
Presentation materials for the June 15 call will be available on the CMS web site (in the "Downloads" section) no later than 24 hours before the conference call. Presentation materials from previous CMS-sponsored calls on the basics of ICD-10 are also available there. Remember to download the presentation materials prior to the call.
The AAFP is working to provide members with ICD-10 information and resources including a transition planning tool and free, members-only ICD-10 coding education modules. Check back often to find new information and resources as these will be published as developed.
2012 will be here sooner than you think
With the business of today to handle, preparing for a change you must accommodate by Jan. 1, 2012 may not seem a high priority. However, the change to the 5010 version of the HIPAA-compliant electronic transaction standards that must be used as of Jan. 1, 2012 will likely require quite a bit of advanced planning, and 2010 is a good time to start. There will be many steps in the process, many of which will require working with software and hardware support vendors, clearinghouses and payers to upgrade systems and conduct testing.
Every entity that sends or receives electronic transactions such as claims submissions, eligibility inquiries, claims acknowledgments and reports must upgrade to the new standards. So, unless you are lucky enough to be one of the biggest customers of your software and hardware support vendors or have persons internally who provide these services, you may want to start vying for attention early.
To help with your planning, the AAFP has put together a checklist that may help you identify the tasks to be performed and create your 5010 transition plan. The checklist provides an example of the steps that may be needed to coordinate upgrades and testing, recognize and plan for expenditures and process changes, and verify successful transmission. Also included are a list of electronic transactions included in the 5010 standard and potential questions to discuss with software vendors/system support staff.
An added benefit of planning now for the transition to the 5010 standards is that implementing them is preparation for the Oct. 1, 2013 adoption of the ICD-10-CM diagnosis code set. The new standards will provide the identifiers necessary for transmission of the ICD-10 codes. Discussions with software vendors about the 5010 transition should also include initial inquiries about the vendors' plans and progress toward an ICD-10 upgrade.
Time flies whether you are having fun or not. Hopefully some early planning and preparation for change will allow for easier transitions and more time for the fun stuff.
ICD-10: Y2K all over again?
People often see things differently. Two neighbors may call their county government offices, one to ask that weeds be sprayed along the road and another asking for a no-spray ordinance. Health care is not immune to such conflicting priorities.
Some are anxiously counting the days until the Oct. 1, 2013, deadline for adoption of the ICD-10-CM codes and the "granularity" they promise. I doubt many practicing physicians are among that group. A letter to the Centers for Medicare & Medicaid Services from Jim King, MD, chairman of the AAFP Board of Directors, left no doubt the AAFP did not support this change. That said, I hope you are not losing sleep, hoarding canned goods or preparing to duck for cover. The transition from ICD-9 to ICD-10 will create some challenges but will not likely result in widespread calamity.
Don't get me wrong. This is not your average annual code update. As reported by the American Academy of Professional Coders, when the Blue Cross Blue Shield Association converted the 164 ICD-9 codes included in FPM's model superbill to ICD-10, the resulting mess was seven pages longer than the original list. (The FPM Superbill has been updated for 2009; you can download it from the FPM Toolbox.) Clearly the ICD-10 code set is cumbersome compared to ICD-9, but it's not as difficult as learning to diagnose and manage the 68,105 conditions that may be reported with ICD-10. You can handle this.
Here are some things to consider as the Oct. 1, 2013, implementation deadline approaches:
1. You will no doubt soon receive ads for ICD-10 products and educational resources. Please don't waste your money. Learning a complex coding system that you will not use for nearly five years isn't productive, and changes could be made to the code set before 2013. Keep reading FPM and plan to learn more when implementation is closer.
2. Don't let ICD-10 overshadow another change with the potential for significant financial impact, especially for solo and small practices -- the conversion to the HIPAA 5010 electronic transaction standards, which must be completed by Jan. 1, 2012. Version 5010 is an extensive revision and paves the way for submission of ICD-10-CM codes. If your software vendor charges for upgrades or floundered during prior changes, now is the time to start asking questions about implementation plans and considering your options (e.g., upgrade or change vendors).
3. If you think you might need to change your software, consider a combined EHR/practice management system. A combined system may relieve some of the ongoing burdens and costs of transitioning to ICD-10. Imagine having an ICD-10 look-up tool similar to the FPM ICD-9 Look-Up Tool built into your EHR and integrated with your billing system, or a system that automatically converts standardized nomenclature to codes.
Most of you have endured the Medicare enrollment process, so you are combat-tested. And you are not alone. The AAFP and FPM will continue to provide you with the best resources that we can find or create to help you make the transition to ICD-10.
The future of diagnosis coding
The Centers for Medicare & Medicaid Services (CMS) announced the future of diagnosis coding for physicians last week. Specifically, on Jan. 16, CMS published a final rule specifying that by
The good news is that you have almost five years to get ready, which is two years longer than CMS originally proposed. The bad news is that you will still have to make systems changes and train yourself and your staff to use the new codes.
In the meantime, you and your practice will also have to comply with an updated X12 standard, Version 5010, for certain electronic health care transactions, including claims, remittance advice, eligibility inquiries, referral authorization, and other administrative transactions. Version 5010 accommodates the use of the ICD-10 code sets, which are not supported by Version 4010/4010A1, the current X12 standard. The compliance deadline is
They say that “forewarned is forearmed.” Please consider yourself “forewarned” and anticipate that Family Practice Management, the