ICD-10 Preparedness and Clarified Flexibilities

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Can you believe we're in the final stretch before the looming ICD-10 October 1 deadline? Well, for some healthcare providers, the thought is still surprising. According to a recently conducted RelayHealth survey of 130 HFMA ANI attendees, 17 percent of participants said they think ICD-10 will be delayed again, while only 13 percent felt they are fully ready for ICD-10.

Within the same survey, 32 percent believed the ICD-10 transition will actually take place on October 1, 2015, but with provisos. A majority of participants (59 percent) thought physicians need more training on documentation, and 39 percent felt coders need more training or opportunity for practice with new codes.

Considering it's already August, providers can't bank on another delay. Instead, they must make sure they have the necessary processes in place for this transition and work with thoroughness and urgency, not panic. Consider the possible problem areas for ICD-10 testing, and be proactive about them.

In the meantime, the Centers for Medicare and Medicaid Services (CMS) has clarified flexibilities after the ICD-10 compliance deadline. Providing a question-answer formatted document, CMS gave feedback to the healthcare industry. However in doing so, CMS has reiterated the release of this FAQ does not indicate another ICD-10 delay.

CMS clarified the following ICD-10 specifications below:

• The ICD-10 ombudsman will be in place by Oct 1.
• If a submitter's claims are denied, they will receive explanation of the rejection.
• Submitters should follow existing procedure for correcting and resubmitting rejected claims.
• CMS will indicate whether a claim is rejected for invalid code versus lack of specificity needed for Local Coverage Determinations or National Coverage Determinations.
• Added ICD-10 flexibility only applies to Medicare fee-for-service claims, but each state's Medicaid program will be responsible for processing submitted claims that include ICD-10 codes for services on or after Oct 1 in a "timely manner."

At this stage in the game, our experts offering the following pieces of advice for ICD-10 preparation:

1. For each physician, make a list of the top 25 ICD-9 diagnosis codes utilized over the past 12 months (Set A).
2. From Set A, have your coding group research and prepare a crosswalk of each ICD-9 code to its ICD-10 counterpart (where there is 1:1 correlation). Note if there are any additional documentation requirements the physician will need to make going forward for Set A.
3. For the subset of codes that do not have a 1:1 match (Set B), have your coding group create a flow chart by code that depicts the required documentation and medical rationale needed in order to identify the correct ICD-10 code. Denote the additional required documentation requirements.
4. Perform physician education.
   • Present Set A and highlight additional recommended documentation that will be needed going forward. For many physician lists, there will be a 1:1 match from the ICD-9 code to its ICD-10 counterpart.
   • Present Set B and highlight the ICD-10 coding requirements (documentation and decision rationale). Work with each physician to personalize education as needed. Remember, it is estimated that an additional 20 percent of time will be required to fully and accurately document the correct ICD-10 code. Time spent in education prior to October 1 will lessen the negative impact on the revenue cycle.
5. For physicians with lists where the majority of codes do not have a 1:1 match, arrange education in small focused groups, perhaps using their medical specialty. The impact of ICD-10 is greater for some medical specialties than others (cardiology, orthopedics, emergency medicine, surgery). Use this knowledge proactively and offer additional specialized education for these physicians as their claims typically show higher dollar values and therefore pose more risk to the revenue cycle.
6. For hospitalists, arrange separate education that includes SNOMED training. The October 1 deadline will also bring a dramatic change in inpatient procedural coding.