68,000 Reasons Why You Should Care About ICD – 10 Conversion
There is less than 90 days until the health care industry moves from the current 14,000 codes in the International Statistical Classification of Diseases and Related Health Problems, Ninth Revision (ICD-9) to approximately 68,000 new codes in the Tenth Revision (ICD-10). Recently, I had the opportunity to sit down with Jennifer Job COO of a national medical billing company, Sun Valley Medical Billing Company.
Judith: Do you think ICD-10 will be delayed?
Jennifer: No – It would literally take an act of Congress at this point and I just don’t see that happening in time for a delay. Last week the Centers for Medicare & Medicaid Services (CMS) announced that it will not deny claims with a nonspecific ICD-10 code for the first year. This will help practitioners “ease” into the new coding system.
Judith: What are your thoughts about the July announcement by the CMS and American Medical Association (AMA) which they are setting up an ICD-10 communications and coordination center to identify and resolve issues arising from the ICD-10 transition? Seems a little too late in my opinion.
Jennifer: This was a push by AMA to have CMS ease up on their requirements for processing a claim that had specific coding in place for a claim to be paid. They announced that for the first 12 months a claim will not be denied for a non-specific code. It added flexibility in the claims audit, quality reporting process and does give us time to train practitioners on what an ICD-10 even looks like. In addition, it allows us to train more efficiently by implementing the “crosswalk” of an ICD-9 code to a corresponding ICD-10 code. With the training in 2015-2016 on specific coding within ICD-10’s, assisting practitioners to correctly code, can potentially eliminate denials of claims, and ensure reimbursement which subsequently eliminates any cash flows issues. I would agree, it appears to be late with only a couple of months to go before we go “live”. I welcomed the announcement requiring the flexibility and appreciate knowing that the AMA and CMS recognize the potential of having practitioners, experiencing severe cash flow issues. Understanding the result could produce devastating results for practitioners, patients, employees and businesses that rely on the medical industry as a source of their business and livelihood.
Judith: How long has your company and staff been preparing for ICD-10? Are you prepared?
Jennifer: We have been upgrading and updating systems for at least three years to prepare for the change to ICD-10. Sun Valley Medical has streamlined our software and have partnered with a software company that has a system that is prepared for the change with us. Our staff has taken specific training for ICD-10 changes and Sun Valley has developed a formal training series for our existing clients and prospects.
Judith: Do you feel the changes will have a huge impact on a specialty practice, or possibility a larger impact could be felt at the Primary Care level? Urgent Care Clinics, etc.?
Jennifer: I feel the largest impact will be with the specialist, especially Orthopedics and Obstetricians, due to the sheer number of new codes that they will be required to use.
Judith: Has your clients analyzed their receivables to see what the impact could be if they are not paid for 90 days due to wrong codes, or incomplete codes? Have any of them obtained additional resources to handle any cash flow short falls?
Jennifer: As a company, our services include the preparation of a monthly revenue cycle report, which we present to our clients. We review these reports with our clients during our meetings. At that time we have been very verbal and up front with our clients regarding the potential impact to their receivables, especially with cash flow issues. Most have responded with either putting some reserves aside or working with their banker on lines of credits.
Judith: Have you contacted your payors as CMS recently suggested to see if they are prepared?
Jennifer: We have – we do bill quite a few different workers’ compensation and lien claims which have not been required by law to change on October 1st. Most of the payors are changing regardless and some have never heard about the changes, which is scary. We have develop a protocol and process internally to provide the ICD-9 codes to those that are still using them. Our upgraded systems allow us to include the ICD-9 codes on those claims that we have identified need to stay with those appropriate diagnosis codes.
Judith: That is scary to know that this is not a uniformed requirement for those that use the ICD coding system to process medical claims. Why do you think that the other providers, such as you mentioned, have not been mandated by this sweeping change to convert? Is this an oversight?
Jennifer: It does seem like an oversight, doesn’t it? CMS states that all covered entities who are regulated by HIPAA, must implement the new code sets with dates of service that occur on or after October 1, 2015. This means that just about every healthcare provider and payer is a covered entity. But there are non-covered entities that are not required to switch, such as workers’ compensation, disability and auto insurers. That is because of the under 45 CFR 164.512, HIPAA Privacy Rule allows these entities to process due to the significant variability among the laws, The Privacy Rule permits disclosures of health information for workers’ compensation purposes. We process these types of claims for our clients, so it does add another layer of potential confusion for proper billing. We have put in place protocol and processes for handling Non-HIPAA covered entities, which ones are switching to ICD-10 and which are not. As I mentioned earlier, our upgraded systems we have in place, handle just that scenario.
There is no doubt that by implementing ICD-10, the United States will be on par with the rest of the developed countries. The new coding system has been in place in some countries since 1994.
Judith Lindsay, owner of JAL Consulting & Associates tackles all the elements of the HIPAA compliance puzzle, successfully assisting organizations to make sense of it all. Judith uses a holistic approach by providing guidance on which policies, procedures and processes are needed for any size or complex organization. Judith's blogs can be found weekly at her Linkinedin account and is available for speaking engagements related to the world of compliance. Connect on Twitter or Linkedin.
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