HIMSS has published an Advisory Report on risks involved in ICD-10 planning and implementation. It is not an exhaustive report of all risks, but it focuses on five key areas of risks. Left unchecked, these issues could have catastrophic consequences for some providers and institutions.
CMS recently sent out a news release on Simple Steps to Improve Clinical Documentation. These steps will assist the clinicians in providing the documentation required to selected the appropriate diagnosis code to the highest level of specificity come October 2014 when ICD 10 takes effect.
As most of us are still learning about the 2013 Psychiatry coding changes, we know that the Interactive Complexity 90785 is used in reporting communication factors that complicate the delivery of psychiatric services. Interactive Complexity represents the difference in intensity of the work. The time of this service is captured in the time of the primary procedure it is billed with.
CMS has announced that there will be no more delays in ICD 10. Come October 1, 2014, ready or not everyone will be required to use ICD 10 diagnosis codes in order to get reimbursed for services performed on or after October 1, 2014.
The Centers for Medicare & Medicaid Services (CMS) announced, on July 7th, that it is making several critical changes to the transition period to ICD-10. They published a document that covers the concessions and how they will affect your practice:
In an article that focused on concessions by CMS, the AMA notes the following changes to implementation:
Claim denials. For the first year ICD-10 is in place, Medicare claims will not be denied solely based on the specificity of the diagnosis codes as long as they are from the appropriate family of ICD-10 codes.
This means that Medicare will not deny payment for these unintentional errors as practices become accustomed to ICD-10 coding. In addition, Medicare claims will not be audited based on the specificity of the diagnosis codes as long as they are from the appropriate family of codes. This transition period will give physicians and their practice teams time to get up to speed on the more complicated code set.
Both Medicare Administrative Contractors and Recovery Audit Contractors will be required to follow this policy.
Quality-reporting penalties. Similar to claim denials, CMS will not subject physicians to penalties for the Physician Quality Reporting System, the value-based payment modifier or meaningful use based on the specificity of diagnosis codes as long as they use a code from the correct ICD-10 family of codes.
In addition, penalties will not be applied if CMS experiences difficulties calculating quality scores for these programs as a result of ICD-10 implementation.
- Payment disruptions. If Medicare contractors are unable to process claims as a result of problems with ICD-10, CMS will authorize advance payments to physicians.
- Navigating transition problems. CMS has said it will establish a communication center to monitor issues and resolve them as quickly as possible. This will include an ICD-10 ombudsman devoted to triaging physician issues.
What you need to do to prepare
They say these concessions should serve to ease the pain of the transition, but there is concern that many will see this as another delay and not place the proper priority on preparation. Preparation is still a high priority. Zetter HealthCare is assisting clients with the most important aspect of preparation for ICD-10 and that is provider education on proper documentation to meet medical necessity and to ensure that the ICD-10 code(s) chose(n) to submit on the claim is documented properly in your HPI, exam and assessment from the notes of the patient encounter.
The CMS-1500 Claim Form has been recently revised with changes including those to more adequately support the use of the ICD-10 diagnosis code set.The revised CMS-1500 form (version 02/12) will replace version 08/05. The revised form will give providers the ability to indicate whether they are using ICD-9 or ICD-10 diagnosis codes, which is important as the October 1, 2014, transition approaches. ICD-9 codes must be used for services provided before October 1, 2014, while ICD-10 codes should be used for services provided on or after October 1, 2014. The revised form also allows for additional diagnosis codes, expanding from 4 possible codes to 12.