October 1, 2015 was the launch and implementation date for ICD-10. For many the transition to ICD-10 has been successful. Others have had a few bumps in the road.
Now what? The conversion is not completely over though. Both Centers for Medicare & Medicaid Services (CMS) and most payers have given the healthcare industry a grace period in which the code to adequate specificity in ICD-10, as long as we are coding in the correct category and laterality is reported. This grace period will not last forever.
What can you do to protect your projected revenue? Have you been relying heavily on electronic health records to select diagnosis codes? The tools in the electronic health record are helpful, but they are just that - tools. By relying on auditing documentation to support the diagnosis codes, ensures the provider is reporting to the highest level of specificity.
Now is not the time to lose sight of achieving compliance within ICD-10. Organizations should be focusing on improving coding and clinical documentation, and improving coding patterns. Both payers and the CMS will begin auditing for specificity and appropriate documentation shortly. If are not able to support your billing, both CMS and payers will be asking for their payments back. Or they will just notify your practice manager of the deduction from your checking account.
By performing an ICD-10 assessment of your coding and documentation, your organization will be in better shape and ready for the storm of requests for additional documentation in the coming months.
What are the steps to an ICD-10 Assessment?
1. Run a frequency report of the most common ICD-10 codes that have been reported from Oct. 1, 2015 to date for each individual provider in your practice, or in the facility by coder.
2. The most frequently used diagnosis codes should be the priority. Begin by randomly sampling 10-20 patient records and audit the claims, looking at the diagnosis code selection along with ensuring that documentation is voluminous enough to support a code to the highest level of specificity.
For example, if the provider indicated that a patient has a pressure ulcer, determine whether the provider has documented the following:
Laterality (right versus left);
Stage of ulcer;
Whether gangrene is present.
If the provider has not documented all the elements above, the documentation is not sufficient to report the pressure ulcer to specificity.
3. Prepare a report with the result identifying the documentation and coding that is accurate versus deficient.
4. Each individual provider should be met with, sharing the results, providing documentation and provide the correct coding, along with any other educational pieces.
Examining the audit reports, monitoring, and providing education will improve your organization’s percentage of coding compliance.
Each organization should determine the compliance percentage that is acceptable. A threshold of 95 percent or below may warrant additional training and support for a provider or a coder. By applying results based accuracy ratio, the organization is ensuring future cash flow.
How often should an ICD-10 assessment (audit) be conducted? That depends on the individual provider results and your organization's standards.
By being proactive, don’t wait until the grace period is over. Internal audits are to assist both providers and coders in improving coding and documentation. Thus, preventing any disputes and fees being returned.
Judith Lindsay, CHP and CEO of JAL Consult tackles all the elements of HIPAA compliance puzzle. Successfully assisting organizations to make sense of it all by implementing the correct policies and procedures that are reasonable and appropriate for their entity. Judith provides consulting, training and is available for speaking engagements. To read more about the world of compliance subscribed to JAL’s insightful newsletter atwww.jalconsultantsaz.comOR follow JAL on Twitter @ judithconsult.
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