Rachel V. Rose, JD, MBA, advises clients on compliance and transactions in healthcare, cybersecurity, corporate and securities law, while representing plaintiffs in False Claims Act and Dodd-Frank whistleblower cases. She also teaches bioethics at Baylor College of Medicine in Houston. Rachel can be reached through her website, www.rvrose.com.
Find out what the recent agreement between the AMA and CMS means for physicians going forward.
With October less than three months away, physicians need to be prepared for the ICD-10 conversion.
By now, everyone in the healthcare industry knows that the effective date for ICD-10 implementation is Oct. 1, 2015. Moreover, because of the multiple delays of the effective date of the transition, there is no excuse for physicians not to be ready to change coding systems. Some larger institutions have already been utilizing the more specific standards of the U.S. version of ICD-10. Specifically, ICD-10 in the U.S. has two categories – ICD-CM and ICD-PCS.
ICD-10 CM is “[t]he International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM) is a system used by physicians and other healthcare providers to classify and code all diagnoses, symptoms and procedures recorded in conjunction with hospital care in the United States,” according to Tech Target. Funded by the U.S. Centers for Medicare and Medicaid, ICD-10–PCS is specific to the United States and is utilized for procedural codes. The biggest obstacle for most physicians and coders is the increased specificity, which translates into a cash-gap increase. If the condition or procedure is not correctly coded, the claim will be denied and have to be re-filed utilizing one of approximately 69,000 ICD-10 CM codes compared to approximately 14,000 ICD-9 CM codes.
On July 6, 2015, the Centers for Medicare and Medicaid (CMS) and the American Medical Association (AMA) issued a joint statement. “ICD 10 implementation is set to begin on October 1, and it is imperative that physician practices take steps beforehand to be ready,” said AMA President Steven J. Stack, MD. “We appreciate that CMS is adopting policies to ease the transition to ICD-10 in response to physicians’ concerns that inadvertent coding errors or system glitches during the transition to ICD-10 may result in audits, claims denials, and penalties under various Medicare reporting programs. The actions CMS is initiating today can help to mitigate potential problems. We will continue to work with the administration in the weeks and months ahead to make sure the transition is as smooth as possible.”
Simultaneously, Representative Marsha Blackburn (R-TN), introduced H.R. 3018, Coding Flexibility in Healthcare Act of 2015. The purpose of the act was to provide a six-month safe harbor period for the transition to ICD-10 for submitted claims. The bill is still in Committee and has not been voted on by either the House or the Senate.
The takeaways for physicians include:
• Utilize the resources available through the AMA and CMS;
• Coordinate with all insurance companies to make sure that their systems are compatible and see if a “test run” can be done on submission claims;
• Review the contracts of EHR providers and see if there is a provision for a subscriber to recover for lost revenue in the event of a delay, glitch or system error in the claims submission process with ICD-10; and
• Be as specific as possible in medical documentation.