The chances of another delay in the implementation of the ICD-10 coding system before Oct. 1, 2015 appear to be hopeless. Efforts have now turned to making the transition period as painless as possible.
CMS has responded to pressure from Congress and professional medical organizations to ease the transition to the new ICD-10 coding system by implementing policies that would reduce the chances of "widespread disruption," as one letter from 13 members of Congress put it. Earlier this month, CMS announced that in addition to providing more training and educational resources, Medicare will not deny payment for claims that have been coded incorrectly due to the learning curve with the new system for the first year of the transition. Medicare will also accept codes that are less specific than the new system requires in this transition period, as long as they are in the proper family of codes.
Robert Wergin, president of the American Academy of Family Physicians, which had been lobbying for such concessions, said that "these important changes will ease the transition to ICD-10 for family physicians and alleviate the threat of claims disruptions, which could devastate family physician practices and threaten patients' access to care."
While these changes have been welcomed with a sigh of relief by many in the medical community, others say they have not eliminated pressure on CMS to keep this transition from becoming a major problem. Robert Tennant, senior policy advisor for the Medical Group Management Association, doesn't think these concessions are enough to prevent what he expects to be "a Wild West" of billing come October.
As such, the MGMA are going in a slightly different direction. "We appreciate the CMS announcement about non-specific codes, but that applies only to Medicare claims. Commercial payers may still call for more granularity. What about practices that can't get their software ready and won't be able to send in any ICD-10 codes at all?" asked Tennant. With this in mind, the MGMA has worked closely with sponsors of legislation that Tennant describes as "complementary to the CMS' recently announced flexibility."
The bill, Coding Flexibility in Healthcare Act of 2015, would require both public and private payers to accept either ICD-9 or ICD-10 during the transition period. In addition, this legislation would require CMS to give a progress report to Congress after three months on ICD-10.
Getting from a bill to a final law is neither a straightforward nor generally a very quick process. However, this bill does not actually need to be passed to be effective, Tennant explained. There is the possibility that CMS will act voluntarily, as happened with CMS's recent concessions. "Pending legislation, " Tennant said, "can send a message that Congress is watching." And if this particular legislation does pass, it will mean that Congress will be ready to monitor the success of the new system once it has been implemented.
It may not be much comfort to practices struggling to get ready for ICD-10, but CMS is under as much pressure as they are.