News from CMS as ICD-10 Implementation Date Nears - McDermott+Consulting

News from CMS as ICD-10 Implementation Date Nears

After years of delay, next month the US health care system will soon be replacing the ICD-9 code set with ICD-10 on October 1, 2015. In recent weeks CMS has made a series of announcements, primarily targeted at the physician community, to assist them during this final stretch in the transition to ICD-10.

After years of delay, next month the US health care system will soon be replacing the ICD-9 code set with ICD-10 on October 1, 2015. According to various media reports, the readiness of the healthcare community for this enormous change varies by sector. Hospitals, health systems and payors seem well poised for a smooth transition. In contrast, there are concerns that some physician practices, especially smaller ones, may be less prepared. In recent weeks CMS has made a series of announcements, primarily targeted at the physician community, to assist them during this final stretch in the transition to ICD-10.

Alternative for Providers Who Have Difficulties Submitting ICD-10 Claims
In a recently released MLN Matters article, CMS acknowledges that some provider billing processes may be unable to accurately submit claims with ICD-10 codes. The providers are encouraged to use different free billing software, MAC provider portals, direct data entry through some contractors, or use paper claims (if a waiver of electronic claims processing requirements is granted). These alternative claims submission options do not provide a waiver from submitting ICD-10 codes on claims. CMS is clear that all claims with From dates after October 1 (for physicians) and Discharge/Through dates after October 1 (for facilities & supplier claims) must include ICD-10 codes. Physicians and Providers are responsible for ensuring that they are able to use some form of claims submission process that can support the use of ICD-10 codes.

ICD-10 Ombudsman Named
During a recent CMS National Provider Call, Acting CMS Administrator Andrew Slavitt named William Rogers, MD as the official ICD-10 Ombudsman. Dr. Rogers, an emergency room physician, is CMS’s Director of Physicians Regulatory Issues Team. In this new role, he will work closely with representatives in CMS’s regional offices to address concerns from physicians. CMS will soon setup a process for physicians to submit issues to the Ombudsman. CMS also announced that they will be establishing the new ICD-10 Coordination Center in Baltimore, MD which will begin operating this month. The mission of the center was described as “managing and triaging issues” related to the transition to ICD-10.

CMS Softens Stance on ICD-10 Compliance for Physician or Other Practitioner Claims
As was previously posted on this website, on July 6, 2015, after months of significant pressure from the American Medical Association (AMA) and other doctor groups, CMS announced a 12-month grace period in their enforcement of ICD-10. While a valid ICD-10 code will still be required starting October 1, 2015, CMS announced that they will not deny physician or other practitioner claims solely for the incorrect use of an ICD-10 code for 12 months after the October 1 compliance date as long as the provider reports a valid ICD-10 code from the correct code family. More information is available on the CMS website.

Specialty Specific “Cheat Sheets”
In recent weeks CMS has issued a series of specialty specific ICD-10 cheat sheets. Each document includes information on common codes, clinical documentation tips and clinical scenarios. These documents have been issued for the following specialties: family practiceinternal medicinecardiologyOB/GYNorthopedics and pediatrics.

Section “X” Codes for New Technology
In addition, earlier in the summer, CMS released details on Section “X” codes that are reported by hospitals for inpatient procedures. These codes will be used to identify new medical services and technologies that are not usually captured by coders, or that do not have the desired specificity within the current ICD-10-PCS structure required to capture the use of these new services and technologies.

Examples of these types of services and technologies include specific drugs, biologicals, and newer medical devices being tested in clinical trials. Section “X” codes will be used to identify new technologies and medical services approved under the new technology add-on payment (NTAP) policy. ICD-10-PCS procedure codes are used only for hospital claims for inpatient procedures. Therefore Section “X” codes will not be reported by physicians, even on those physician claims submitted for inpatient services.

More details about Section “X” codes can be found in a recently released MLN Matters article. Visit the CMS website for more information on ICD-10 implementation and stay tuned to this website for additional key updates.