SGR & ICD-10

Late last night, the House Rules Committee authorized legislation to go to the floor of the House that would delay for one year, the SGR related cuts in physician fee schedule payments scheduled to take effect on April 1.  Under this legislation, those cuts would be delayed until April 1, 2015.

In addition, the bill would make a number of other changes in the Medicare program, not least of which would be a one-year delay in the ICD-10 transition.  Under this bill, the Secretary of HHS would be prohibited from mandating use of ICD-10 until October 1, 2015.

The bill would also “extend” a variety of expiring provisions previously extended by Congress.

The bill is scheduled for consideration by the House on Thursday, March 27th under “suspension” (i.e. House temporarily suspends normal rules).  In order for the House to take up this bill under “suspension,” a two-thirds (2/3) majority must agree to consider this bill.  It is not clear whether the House Leadership has the two-thirds (2/3) majority votes.

A bill brought before the House under “suspension” cannot be amended.

HBMA Testifies on ICD-10

Shaking handsDue to the large role the Healthcare Billing and Management Association (HBMA) plays in revenue cycle management, the HBMA was invited to participate in discussions with the National Committee on Vital and Health Statistics (NCVHS) subcommittee standards on the process of transitioning from ICD-9 to ICD-10 on October 1, 2014.

Holly Louie, CHBME, Chair of HBMA’s ICD-10/5010 Committee presented HBMA’s views on what they considered “lessons learned” from the 5010 conversion that took place in January 2011, and how those lessons could apply to the upcoming ICD-10 conversion.

Louie was one of many experts invited to address the NCVHS. In her address she said, “HBMA believes that we MUST learn from the mistakes that were made in transitioning from 4010 to 5010, and undertake the transition from ICD-9 CM to ICD-10 CM in a way that demonstrates we learned those lessons.” She shared the HBMA’s concerns with the committee and of how those “lessons learned” from 4010 to 5010 should “materially inform the implementation of ICD-10”. She further explained to the committee, “the economic stability of America’s healthcare reimbursement system will be at risk and could be severely compromised, affecting provider financial viability and patients’ access to care.”

The Centers for Medicare and Medicaid Services (CMS) have already delayed the implementation date of ICD-10 to October 1 2014. With this delay Louie said, “it is imperative that the time gained by the delay be used wisely in order to ensure that the transition is successful. If we fail to learn the lessons we will merely be delaying the likelihood for payment disruptions and patient access to care problems from 2013 to 2014.”

HBMA strongly recommends the following:

1. While CMS has adopted a definition of “ready” and developed the tools and checklists to assist every provider, organization, payor and vendor to validate they are ready on October 1, 2014, a subsequent announcement by CMS that they will not perform any external testing is extremely problematic for the industry. End-to-end testing by all payors, to meet the definition of “ready” must occur to ensure a smooth ICD-10 CM implementation. Failure to engage in meaningful end-to-end testing is a recipe for disaster.

2 CMS must establish period benchmarks that cannot be ignored to assess the “readiness” status for all facts of the healthcare industry.

3. There must be clear pronouncement that there is no vendor, EHR, coding assist tool, map, crosswalk or other product that will solve the problem of excellent medical record documentation and accurate coding. Physicians and staff must be fully prepared with adequate training to operate compliantly and not rely on false proclamations of marketed solutions.

4. Payor policies will be critical to the appropriate adjudication of claims. Currently, there is a wide variance among payors in stated policies. It is imperative that policies are published by October 1, 2013 in order to allow adequate time for education and training, data analysis and other preparations for ICD-10 CM.

5. Any payor that is currently only accepting claims by 4010 format must be fully 5010 compliant by January 1, 2014 in order to be ICD-10CM ready.

HBMA’s expert remarks were made on behalf of the membership with the goal of making this transition as smooth as possible for the entire medical community.

 

SOURCE: Healthcare Billing and Management Association

Website: www.hbma.org

Improving Documentation

1314902_medical_doctorThe purpose of ICD-10 is to provide more detailed information on the care being provided. There are many steps that need to be taken in order for a practice to prepare for the ICD-10 conversion that is coming October 1, 2014. One of the key changes that will need to be made by some, if not most, physicians is what type of information is being documented in a patient’s medical records and determining whether that information is enough.

Looking at how diagnosis information is being documented will help physicians and coding staff be better prepared for the ICD-10 switch.

Here is a suggested process on how you can better prepare your documentation for ICD-10.

Pull a handful of medical records on some of your more commonly used diagnoses. Review those records with your coding staff, and have them determine if your current documentation provides enough information to associate the appropriate ICD-10 code. If it doesn’t, then you’ll know improving documentation is a necessary change for your practice.

But what kind of information are you supposed to include in your documentation to be able to code for ICD-10???

The best way to think of what the differences are between ICD-10 and ICD-9 is to think of ICD-10 as “expanded”. Most diagnoses in ICD-10 are expanded to include things like body locations, types, causes etc. Laterality is an example of what is expanded in ICD-10. So, documentation for diagnoses needs to include information on which side of the body is affected (right, left, or bilateral). Below are a few other examples of how ICD-10 is expanding on a particular diagnosis and the documentation that will need to be in the medical records.

Fractures –

  • Site
  • Laterality
  • Type
  • Location

Injuries –

  • External Cause – You will need to provide “how” the injury occurred.
  • Place of occurrence – Where did the injury take place?
  • Activity code – What was the patient doing that caused the injury?
  • External cause status – Indicate if the injury was related to another source (military, work, etc.)

Diabetes Mellitus –

  • Type of Diabetes
  • Complication or manifestation
  • Body system affected
  • If type 2 diabetes, long-term insulin use

Making your documentation as detailed as possible will help your coding staff assign the appropriate codes and help reduce the potential for rejected claims. ICD-10 shouldn’t affect patient care. All it is doing is requiring more detailed information. Most of the information is likely already being provided to you during the patient’s visit. It is just making sure you’re recording everything your coding staff will need to chose the correct code.

Improving documentation will improve coding staff turnaround time on billings and in turn reduce the amount of rejected claims for coding issues and so will help you to maintain a consistent revenue stream.

 

ICD-10

141,000!!

What is that 141,000 number mean? That is just the total number of ever more specific diagnosis codes that comes along with the Tenth Edition of the International Classification of Disease (ICD-10). A little bit of an increase from the Ninth Edition (ICD-9) which totaled 17,000 codes. The department of Health and Human Services (HHS) extended the compliance date from what would have been October 1 of this year, to October 1, 2014. Although the date has been pushed back once again, HHS urges all covered entities under the Health Information Portability and Accountability Act (HIPAA) to continue, or start, preparations for the transition to ICD-10.

A transition of this magnitude requires extensive planning and preparation in all aspects of a medical practice and throughout the industry. It is recommended that timelines be established as soon as possible to help manage tasks and keep the transition from becoming too overwhelming.

The Centers for Medicare & Medicaid Services (CMS) have created an example timeline to help illustrate the process. Click the link below to view the timeline.

http://www.cms.gov/Medicare/Coding/ICD10/Downloads/ICD10SmallMediumTimelineChart.pdf

What does this mean for a physician?

Most changes will be on coding and coding staff becoming familiar with the new format of codes and the multiple options for a specific diagnosis. It will also take some coordination from physicians in being more specific with their diagnosis when charting. In ICD-9 there would typically be one option for a particular condition, where as in ICD-10 there may be multiple. Below is an example of of the differences of what is reported using ICD-9 and what will be required with ICD-10.

Example: 1                                      

ICD-9

784.0 – Headache

ICD-10

G441 – Vascular Headache Not elsewhere classified

R51 – Headache

Example: 2

ICD-9

784.59 – Speech Disturbances

ICD-10

R4702 – Dysphasia

R4781 – Slurred Speech

R4789 – Other Speech Disturbances

Note: ICD-10 will not affect CPT codes.

Although diligent efforts are being made industry wide for a smooth efficient transition, a change of this scale is not without it’s bumps and hiccups, foreseen and unseen alike. Payment, and claims processing delays are a major concern. With the 5010 transition last year which was the electronic claim file format upgrade from 4010, payment and claims processing delays did cause cash flow problems nationally. Cash flow is a major concern to any organization, group, private practice or covered entity under HIPAA. To help organizations prepare as best they can and avoid cash flow issues, it is being recommended that organizations begin preparations now! Some consultants have also suggested providers and organizations build a line of credit that can sustain them anywhere from two to six months after the compliance date to manage delays in payments.

Training of coding and other staff is also a vital component for preparations for the ICD-10 transition. Studies showed that after the ICD-10 transition in Canada, staff productivity dropped by 50 percent in the first six months. A drop in productivity means that fewer patient claims will be submitted timely and more money paid to staff for increased time thus affecting cash flow and the bottom line. It is imperative that physicians and organizations help staff to understand the importance of preparing for the transition to avoid productivity drops.

Contacting vendors is also another key cog in the wheel of preparation. Contact and follow up with, EHR/EMR vendors, billing software vendors, outsourced billing providers, electronic clearinghouses, and payers. Software testing with clearinghouses and payers will typically be handled through the software vendors, or outsourced service providers but none the less, providers and organizations should follow up to ensure preparation and timelines have been established.

Some helpful hints to plan for the ICD-10 transition:

  • Start a plan
  • Establish a timeline
  • Contact vendors
  • Staff Training
  • Build a line of credit

If you’re asking yourself, “when do i start planing for ICD-10?”. THE TIME IS NOW!