The U.S. is 15 months from the ICD-10 transition. Amid confusion over the as-yet-undetermined compliance date, rumors and incomplete information are spreading about its coming use. This article supplies honest answers on those topics and provides guideposts for your ongoing transition planning.
Your documentation will need to be complete, now more than ever. Using ICD-10 may require more attention to detail. However, for those who already use specific, precise documentation, there won't be much of a change. The specificity of the codes is a large part of what is driving the mandate. Complete documentation of the patient's condition is key to determining the best diagnosis code.
You do not need to know all the codes in ICD-10-CM. Most internists will be using a subset of diagnosis codes for most of the claims they submit to payers. However, some medical conditions do gain many more diagnosis codes than they had in ICD-9. For example, where ICD-9-CM has 59 codes for diabetes, ICD-10-CM will have more than 200 codes. This particular expanded code set has added the specification “poorly controlled” to the categories of “controlled” or “not controlled,” along with multiple combination codes (e.g., ICD-10-CM code E09.11 designates “type 1 diabetes mellitus with ketoacidosis with coma”).
Coding tools, such as crosswalks and conversion indexes, will be available to help you build your set of frequently used ICD-10 codes.
The compliance date remains Oct. 1, 2013. On April 17, 2012, the Centers for Medicare and Medicaid Services issued a proposed rule to delay the compliance date for use of the ICD-10-CM and ICD-10-PCS code sets. ACP sent its written comments and recommendations to CMS, encouraging the agency to delay the compliance to at least Oct. 1, 2014, to give the medical community sufficient time to complete transition plans and activities. At this writing, CMS had not made its final decision. ACP's inquiries to CMS officials find that the agency is still reviewing and considering the 500-plus comments it has received.
Questions to ask your software vendors
Medical Group Management Association representative Robert Tennant, speaking to an electronic data interchange forum, offered these questions as suggested topics for discussions/negotiations with vendors:
- Is the vendor aware of the ICD-10 regulation and other regulations that will impact the functionality of its product?
- What is the vendor's schedule for ICD-10 system upgrades and training, and how does it compare with the practice's schedule?
- Will the vendor's products be able to support both ICD-9 and ICD-10 at the same time during the transition?
- How long will the upgrade/installation take? What impact can a practice expect it to have on daily operations?
- Is the coding software vendor going to upgrade the current version of the software, or will a newer version need to be purchased? Will it have an electronic health record (EHR) or practice management interface?
- If the vendor's product has an EHR interface, does it meet the meaningful use standards?
- Is the vendor able to deliver a product(s) that can help the physician meet the regulatory and statutory requirements of ICD-10?
- When will the practice be able to send ICD-10 coded claims transactions to the claims clearinghouse for testing? Is the clearinghouse using the CMS ICD-10 general equivalence mappings (GEMs), also known as crosswalks?
- Will the clearinghouse notify its customers about any changes to coverage and reimbursement that result from using ICD-10? Will it notify customers about data content changes that ICD-10 requires?
Depending on the answers you receive, you may want to give your contract serious review, or find a different vendor whose product(s) can meet your needs.
Continuing steps toward ICD-10 implementation
The transition will also require discussions with any other information technology vendors whose product intersects with ICD-10. Be sure that you've planned for these items:
- software updates,
- a review of health plan contracts,
- modification of office superbills (if you are still going to try to use them) and other coding documentation, and
- general implementation of these changes into the office workflow.
You should have already created your implementation plan, spoken with the practice's key stakeholders about the ICD-10 transition, and performed impact assessments for your practice's systems, applications, documentation processes, workflow and policy implications.
You should also have developed budget plans that include your consultant contracts, software purchases, staff training, reprinting of forms and documents, and preparation for internal testing of these systems.
At this point, practices should be well into assessing the quality of their medical record documentation, implementing any documentation improvement strategies that may be necessary, and monitoring the impact of documentation improvement strategies. The coders should be gaining more familiarity with ICD-10 code sets, although intensive coding instruction for most staff is not needed at this point.
As you move through your ICD-10 implementation plan, remember to:
- stay in touch with business associates and follow up on their readiness;
- refine your practice's project plan, timeline(s), and budget as necessary; and
- develop a contingency plan for continuing critical operations in case problems occur when the ICD-10 implementation goes live.
About a year remains until the scheduled compliance date for ICD-10 arrives. Make the best of use of that time to get your practice ready for the transition. If you haven't done it in a while, review your implementation plan and ensure that things are moving forward. The goal is for every practice to be claims-submission ready on or before the Oct. 1, 2013 compliance date.