February 23, 2015

The compliance deadline for ICD-10, as you have read many times, is October 1, 2015.  After three delays since the deadline was originally set for 2011, there may be some doubt—not to say cynicism—about whether the October 1st date will slip too.  It may—but the majority of viewers believe that the transition to ICD-10 codes will occur as scheduled.

On February 11, 2015, the U.S. House Energy and Commerce Subcommittee on Health held a hearing entitled "Examining ICD-10 Implementation.”  The seven witnesses who testified were health industry professionals representing such major players as the American Health Information Management Association (AHIMA), Athena Health, America’s Health Insurance Plans (the commercial payers’ lobby) and 3M Health Information Systems.  Six of the seven witnesses adamantly supported October 1st implementation.  The seventh, William Jefferson Terry, MD, of the Mobile Urology Group and American Urology Association, made the usual arguments that ICD-10 coding will interfere with treating patients, prompting Rep, Gene Green (D-TX) to comment to Terry that must have felt as though he was at the Alamo.

Carl Natale of ICD-10 Watch (Why the prognosis for ICD-10 implementation looks good, posted February 14, 2015) considered the line-up of witnesses (selected by the Health Subcommittee) and observed that the hearing “should leave us with the impression that this wasn't a fact-finding exercise but an opportunity to support an action that is coming.  That action is ICD-10 implementation on Oct. 1.”  Dan Bowman, posting on the FierceHealthIT website (With ICD-10 now on Congress' radar, it's put up—not shut up—time, February 15, 2015) reached the same conclusion:  “The whole production, from a bird's eye view, had the feel of a dog-and-pony show in favor of implementation. After all, those running the hearing—Reps. Joseph Pitts (R-Pa.) and Fred Upton (R-Mich.) —could very well have invited other dissenters to the party.”

Natale also looked at the other side and allowed that there might be a fourth delay if CMS experiences technical difficulties such as those that afflicted the rollout of Obamacare.  “Otherwise, Congressional leadership seems to be on board with ICD-10 implementation this year— “ as is most of the health care industry.

It follows that everyone should be proceeding so that they are ready to use the ICD-10 codes by the deadline.  In fact, they should be well along in the major steps to manage the risks associated with the change in code sets:

• Planning,
• Communicating and training,
• Assessing and improving workflow,
• Testing software and processes,
• Implementing and
• Surviving post-implementation

For more information on these steps, which by now are probably familiar to many readers, see Darlene Helmer’s article ICD-10 is the Latest Y2K: The Potential Impact on Provider Revenue in the Spring 2014 issue of the ABC Communique.  AHIMA’s white paper ICD-10-CM/PCS Transition: Planning and Preparation Checklist is also a valuable resource.  Suffice it here to emphasize several specific points:

1. The key to successful diagnosis coding under ICD-10—as for ICD-9, and CPT procedural coding for that matter—is documentation.  The documentation must provide sufficient information to allow the selection of the correct code.
2. Physician engagement is indispensable to a smooth transition.  And:  “Physician education should be succinct. It should focus on clinical concepts, not coding rules and conventions, and tell physicians what they are specifically not documenting, not what they should be documenting.”  (Bloomrosen M.  Achieving ICD-10-CM/PCS Compliance in 2015: Staying the Course for Better Healthcare—A Report from the AHIMA 2014 ICD-10/CAC Coding Summit. Perspect Health Inf Manag. 2015 Winter; 12(Winter))
3. Medicare’s medical necessity policies are set forth in Local Coverage Determinations (LCDs) and National Coverage Determinations (NCDs).  LCDs and NCDs typically base the existence of medical necessity on the presence of specific patient conditions identified by ICD code.  Numerous such LCDs/NCDs have been and are being updated in anticipation of the changeover to ICD-10.  Anesthesia and pain practices should become familiar with the redefined ICD-10 codes that demonstrate medical necessity for services and procedures of interest.  As an example, Cahaba’s LCD  L34289 applicable in Alabama for services performed on or after October 1, 2015 lists 51 ICD-10 codes or code groupings that support medical necessity for continuous peripheral nerve blocks and reminds physicians that “ICD-10 codes must be coded to the highest level of specificity.”

Testing the ability to submit ICD-10 claims to your carriers is critical.  Systems should be tested for eligibility, authorization, claims, remittances and quality reporting; the results should be reviewed to evaluate accuracy, to categorize the reasons for denials and rejections and to confirm that payments are as expected.

CMS has made two kinds of testing available: (1) acknowledgement testing and (2) end-to-end testing.

1. Physicians may submit acknowledgement test claims any time up to the October 1, 2015, implementation date.  In addition, special acknowledgement testing weeks in November 2014, March 2-6, and June will give submitters access to real-time help desk support and allow CMS to analyze testing data.  Registration is not required for these virtual events.  CMS advises you to contact your Medicare Administrative Contractor for more information about acknowledgment testing.
2. CMS has also facilitated end-to-end testing for a small subset of submitters to test claims adjudication.  During three week-long periods this year, 50 providers selected at random from a list of volunteers will be able to participate in testing with each MAC.  Interested practices should check their MAC websites for the volunteer application forms, which must be posted by March 13th and returned to the MACs by April 17th for the third and final testing period which will take place in July.  Further information will be available in a conference call with CMS staff scheduled for Thursday, February 26; 1:30-3pm ET.  You may register for the ICD-10 Implementation and Medicare Testing MLN Connects™ National Provider Call at http://www.cms.gov/Outreach-and-Education/Outreach/NPC/National-Provider-Calls-and-Events-Items/2015-02-26-ICD10.html?DLPage=1&DLSort=0&DLSortDir=descending.

Eight months away from the implementation deadline, it seems highly likely to us that implementation is now going to go forward as scheduled.  The last delay cost the healthcare industry approximately $6.8 billion and there is little appetite for further waste.  Moving to ICD-10 is a huge hurdle but one that none of us can avoid any longer.  Let us hope that the transition is smooth.

With best wishes,

Tony Mira
President and CEO