In August, the Department of Health and Human Services (HHS) issued a final rule which delayed the transition to ICD-10 until October 1, 2015, one year away. Prior to the enactment of the Protecting Access to Medicare Act of 2014 (PAMA), the health care industry was preparing to transition to ICD-10 by October 1st of this year. Last week the Centers for Medicare and Medicaid Services (CMS) published the official ICD-10 Guidelines for Coding and Reporting.
CMS explains that these guidelines should be used in conjunction with the official version of the ICD-10-CM as published on the National Center for Health Statistics (NCHS) website.
ICD-10
The International Classification of Diseases, 10th Revision (ICD-10) is an update to ICD-9, the official system for assigning codes to medical diagnoses. The codes provide an alphabetical index to all disease entries and a classification system for procedures.
The U.S. has lagged behind other countries in updating to ICD-10, but the process is by no means a quick fix. The number of procedural and diagnostic codes is estimated to increase from about 17,000 unique codes in ICD-9 to over 140,000 unique codes in ICD-10. A procedure like an angioplasty, for example, will shift from having 1 code to having 854 possible codes, reported MedPage Today. Needless to say, doctors have been wary about the change.
Due to the vast amount of new data in the update, many doctors and other stakeholders have urged CMS to delay implementation to give everyone involved enough time to prepare for the changes. In a release, CMS notes that ICD-10 significantly impacts the entire health care community. “As such, much of the industry has already invested resources toward the implementation of ICD-10. CMS has implemented a comprehensive testing approach, including end-to-end testing in 2015, to help ensure providers are ready. While many providers, including physicians, hospitals, and health plans, have completed the necessary system changes to transition to ICD-10, the time offered by Congress and this rule ensure all providers are ready.”
CMS rule
In its rule, CMS acknowledges that all segments of the health care industry have invested significant time and resources in financing, training, and implementing necessary changes to systems, workflow processes, and clinical documentation practices in order to prepare for ICD–10.
The rule cites an American Academy of Professional Coders (AAPC) June 2014 survey, which found that of 5,000 AAPC members, nearly 75 percent of the survey respondents reported that they are making significant progress toward preparing for ICD–10 implementation. The survey also indicated that about 25 percent of those surveyed had completed all of the necessary ICD–10 training; 13 percent indicated that they were prepared for the October 1, 2014 implementation date; and 23 percent were actively testing with their ICD–10 vendors when PAMA was signed into law.
Longer delay?
CMS argues that a 1-year delay, as opposed to a longer delay, is the least expensive option for industry. As estimated in the 2012 ICD-10 Delay final rule and repeated in the recent final rule, a 1-year delay increases costs for covered entities by a range of 10 to 30 percent. CMS concludes that a delay beyond 1 year would be significantly more costly and have a damaging impact on the healthcare industry. For example, extending the delay beyond 1 year could render current ICD–10 system updates and releases obsolete, which would diminish the investments stakeholders have already made to prepare for the ICD–10 transition. Stakeholders would need to restart their system preparation and would not be able to leverage past system investments.
Physicians have been leading charge for delays
Physician groups led the charge in opposition to the 2014 deadline, citing a host of potential problems. Those included the inability of many vendors of electronic health records and practice-management systems to have their ICD-10 updated systems delivered in enough time for physicians and their staffs to have them installed; train themselves on how to use them; and have the claims generated by them adequately tested against the systems and rules of their health plans and claims clearinghouses.
Advice for physicians and healthcare organizations
Donna McCune, CCS-P, COE, CPMA, and vice president of the Corcoran Consulting Group, offers some advice regarding the delay with a focus on ophthalmology practice. McCune initially advices physicians to seek out the ICD-10-CM Manual, which contains four more chapters than ICD-9 and the number of code choices increases from 14,000 to 69,000. “The guidelines published in the beginning of the manual are extremely instructive and provide a review of ICD-9 guidelines as well as introduce some subtle changes to coding with ICD-10,” she notes.
Her full report can be found here, and selected questions and answers are printed below:
Q. Should I continue to train my staff during this delay?
A. This is a great opportunity to better prepare them for ICD-10. Non-clinical staff will benefit with additional training on medical terminology and anatomy of the eye. The specificity of ICD-10 requires a higher-level understanding of ophthalmology for proper code selection. Technicians and scribes can improve their documentation, especially with history taking. A fair amount of information required for proper ICD-10 code selection will come from the patient’s history.
Q. Is there any value in practicing our ability to select an ICD-10 code?
A. Yes. By beginning to dual-code some encounters with ICD-10 codes, you will reveal vulnerabilities in your chart documentation that make code selection difficult or impossible. In addition, the more familiar you and your staff become with the manual, the less intimidating it will be in October 2015.
Q. Are some ophthalmic diseases coded differently in ICD-10 than ICD-9, and will this necessitate a change in my current documentation?
A. Yes, there are several. Glaucoma is a good example of a disease that is coded differently. Many physicians are lax with documenting the stage of glaucoma in a patient’s medical record. Currently, few payers, if any, will deny a claim that does not contain the ICD-9 stage code. With ICD-10, your ability to select a code for glaucoma will require that the disease stage be documented.
…Physicians currently not documenting the stage of glaucoma should begin to stage the glaucoma now so that it is not a burden when ICD-10 coding begins.
Q. What other documentation changes should we consider making?
A. Because ICD-10 codes are more specific than ICD-9, there are many changes you can begin to implement.
1. Are your assessments as specific as possible? For example, if you note a corneal ulcer in your impression, are you indicating whether it is a central corneal ulcer, or a marginal ulcer or a perforated corneal ulcer?
2. Are your assessments specific to which eye or eyelid? For example, do you note in the impression if the patient has a chalazion on the left lower or left upper lid as opposed to just noting chalazion? Is the patient’s nuclear sclerotic cataract in her right eye, left eye or both eyes?
3. For patients with a systemic disease and an ocular manifestation, are you indicating both the disease and the manifestation in the impression?
Improved documentation in the impression will facilitate more efficient selection of ICD-10 codes. It is not too soon to begin to make these changes in your current medical records.
Q. Should we wait on ICD-10 and begin to prepare for ICD-11?
A. No. ICD-11 only exists in draft form and is not expected until 2020 or 2025.