Monitoring ICD-10 Post-Implementation Issues

November 16, 2015

ICD-10 is here, so be sure your medical practice is addressing all related issues to avoid a hit to your bottom line.

Planning and execution efforts toward successful ICD-10 implementation have been the largest resource-intensive undertaking by healthcare in decades. The last couple of years have enlisted dedicated planning by government agencies, healthcare plans, EHR vendors, and health information educators in facilitating the transition from ICD-9 to ICD-10.

The cost of ICD-10 preparation was a valid concern for healthcare. Physicians and other qualified healthcare providers were impacted financially with making initial capital investment in certified EHR systems. The cost of initial training for their private clinics or group practices added to expenditures. Time and resources have been allocated to electronic data exchange testing over two fiscal years in anticipation of possible system interface and program incompatibilities. Concurrently, healthcare professionals had prepared for the code system changes by participating in provider-to-vendor testing while EHR companies, clearinghouses, and healthcare plans have been focused on vendor-to-payer data transmission.

The healthcare industry had ample time to analyze the factors that currently affect efficient and uninterrupted quality healthcare, but have healthcare providers anticipated the factors that will affect their practices after implementation?

A national effort to transition to a new and improved, but vastly different coding system inevitably affects various groups and multiple healthcare transactions. As a result of inaccurate data capture and delays in medical billing, it is critical that providers and administration examine how ICD-10 impacts patient care and reimbursement.

There are different factors that contribute to inferior health data reporting and to delays in provider cash flow:


1. EHR keywords tend to mimic the alphabetic index of the code book and are not set up in user-friendly clinical terms. Physicians and other qualified healthcare providers may have difficulty in locating the most specific and accurate ICD-10 code when using keyword search and look-up tools in their EHR.

2. Physician documentation practices may not correlate to main terms and subterms in which the ICD-10 code book or electronic code books are organized, making it more challenging for coders or other designated staff members to find the most appropriate code based on the completed notes.

3. Lack of physician engagement and the decision to not seek training in ICD-10 documentation lends itself to inconsistencies of code assignments from one healthcare provider to another. Many EHR products carry over the diagnosed conditions in the patient's current and past medical history. Other providers from the same practice may choose to assign these same ICD-10 codes previously noted in the record. Even if the providers were to decide to assign their own code and not carry over the previous ones, the lack of uniformity in the practice not only implies that there are coding errors being made, but that the data collected by insurance carriers, independent research groups, government agencies, and public health organizations is not a valid representation of current illnesses. Additionally, incorrect data exchanged across electronic systems is useless information and potentially harmful to the patient's health when shared with outside healthcare providers and facilities involved in the care of the same patient. The movement toward ICD-10 was fueled by a critical need to improve the quality and effectiveness of patient care. Inconsistent and inaccurate data quality thwarts this purpose.

4. General Equivalent Mapping (GEMs) resources are intended to provide the most approximate equivalent code from ICD-9, cross-walked to each possible ICD-10 code. The translation is not a perfect one because ICD-10 includes a plethora of information that previously had not been part of the ICD-9 code description. For example, ICD-10-CM introduces combination codes that detail the underlying disease and current manifestation, routinely seen in diabetes affecting other organ systems. The new coding system has established several new concepts and features for

ICD-10 diagnostic codes, allowing providers to:

• Include information on laterality

• Identify if it is the patient's initial encounter

• Identify the gestational trimester in which the disease process was diagnosed (including the severity of illness)

• Include the external cause

• Expand on the description of injuries, fractures, complications, adverse effects, and poisonings to now include very particular information, such as:

– The Gustilo grade of an open fracture

– If underdosing or noncompliance is due to medication cost-reduction

– If the provider is treating a pregnant patient for a particular condition that first developed during the mentioned trimester and not the episode of care that she presented for

– If the resulting complication resulted intraoperatively or postoperatively

While GEMs serve as a time-saving tool, the matching ratio from ICD-9 to ICD-10 is most frequently not a perfect 1:1 correlation. Most ICD-9 codes will map out to multiple possible options for correct ICD-10 code selection. Exclusive reliance on the GEMs will lead to incorrect code submission on billing claims.


1. The medical profession continues to be reimbursed on our current fee-for-service (FFS) system. National and Local Coverage Determination policies issued by CMS list and detail the diagnostic codes for symptoms and conditions that necessitate commonly performed diagnostic or therapeutic procedures. These acceptable diagnostic codes support the ordering or performing of any diagnostic tests or treatments. Incorrect ICD-10-CM assignment increases the number of "medical necessity" denials for CPT and HCPCS II procedures billed by physician practices.

2. CMS released data on healthcare providers, clearinghouses, and billing companies that participated in their July 2015 end-to-end testing with MACs and DMEs. Medicare published information stating 29,286 claims were received, but only 25,646 were accepted. Additionally, 52.7 percent of all submitted claims were professional services from healthcare providers, 2.6 percent of claims denied by CMS were due to submission of invalid ICD-9-CM codes, and 1.8 percent were due to invalid ICD-10 codes. This 4.4 percent denial rate was higher than the 3 percent reported in April's end-to-end denials. Health information managers (HIM) and providers spent 36 years learning how to assign three-digit to five-digit codes for a complete code selection. Now, providers and coders have to correctly select the required number of alphanumeric characters - anywhere from three characters to seven characters. Denials for invalid code submission further delay provider reimbursement.

3. Code assignment errors increase with untrained clerical and ancillary staff responsible for reviewing billed codes. Coding errors include: incorrectly assigned unspecified codes, codes of lesser specificity, missed diagnostic codes, and symptoms. This is especially critical for practices engaged in the HCC Risk Adjustment coding incentives in which captured data for severity of illness and comorbidities is directly tied to annual financial incentives for the practice.

4. The nearly quintuple growth in available diagnostic codes presents challenges when physician practices redesign their encounter form or superbill. Practices have to be selective about which commonly used diagnostic codes will be featured on the superbill for quick reference and which will be excluded.

5. Medical coders increase the number of queries addressed to healthcare providers for incomplete documentation and unspecified diagnostic conditions. While this is most likely to occur in the inpatient setting, physician practices with in-house medical coders will have billing claims held until the providers adequately respond to clarification requests.

6. Productivity rates decrease because of the increased time required to document properly for specific codes. Medical coders and HIM professionals take additional time to accurately locate and sequence the appropriate codes based on documentation. The increase delay in billing the professional claims increase the number of days in A/R and adversely affect the practice's cash flow. Independent providers and provider practices had been advised to budget for the anticipated financial impact at least six months prior to implementation.


Several measures should be taken in order to streamline the transition in medical practices. Examination and revision of internal policies and processes is essential to ensuring that quality patient data is captured, while maintaining compliance in billing practices.

1. Provider practices should seek assistance from the EHR vendor.

• Vendors are best equipped to provide training and can also instruct office managers on how to run reports detailing the 50 most commonly used diagnostic and symptom codes in the practice.

• EHR companies can effectively re-label many diagnostic codes so that the keyword or main term appears as the clinician deems natural, and not necessarily as the medical coder is trained to look them up in the alphabetic index of the code book.

2. Practices should rely on industry resources for proper coding guidance.

• The American Hospital Association (AHA) publishes quarterly guidance on ICD-9-CM and now ICD-10 code assignment. Many challenging coding questions have been posed to the AHA by medical coders and the responses are available and organized by ICD-9 and ICD-10 codes.

• CMS has publicly released physician guidance on ICD-10-CM coding in multiple medical specialties. Information tips are available to registrants of their listserv. Also, the "Road to 10" online resources are specifically designed to assist physician practices in raising awareness and promoting physician engagement, as well as offering free training for physicians and other healthcare providers.

• The National Center for Health Statistics (NCHS), an agency under the Centers for Disease Control, has additional resources. NCHS offers official guidelines on proper ICD-10-CM and ICD-10-PCS code assignment.

• The ICD-10-CM/PCS Transition Workgroup is an online community forum hosted and managed by the NCHS (on phConnect Collaboration for Public Health) to assist physicians in this implementation (visit for more information).

• The American Health Information Management Association (AHIMA) offers a number of physician coding resources, including an "ICD-10 Toolkit" developed in 2012 which still proves relevant and instrumental today (visit for more information).

• The AMA has printed and electronic ICD-10 publications on coding and documentation intended for providers. They offer online and live training for physicians.

Practices will need training and retraining after reevaluating post-implementation operations. Staff members come and go and providers may take medical posts in other organizations. Consistent and high-quality data reporting is essential and will directly impact practices as our healthcare industry phases out the FFS model and moves toward a value-based payment model. Practices should be making provisions for educational reinforcement after ICD-10 implementation, and should strongly consider the benefits of employing certified medical coders and HIM professionals.


The financial health of physician outpatient practices is affected by accurate ICD-10 coding. Just as importantly, patient health outcomes are directly tied to proper coding. Proper planning is key to compliance and optimal revenue management.

Continuing education and employment of certified coders will minimize coding errors. Close monitoring of the revenue cycle and reassessment of internal processes will help identify gaps. Utilizing industry resources is a cost-effective means of improving processes. All of these combined are ingredients in the best recipe for post-implementation success.

G. Elizabeth Wilson, BS, RHIT, CCS, CPC, CEMC, CPMA, CPCO, CHC,is the director of coding and auditing, and the compliance and privacy officer for New York-based Healthcare Solutions WNY, LLC. She can be contacted at