12 Things You Need to Know about ICD-10 Implementation

With the ICD-10 deadline fast approaching, it is important to know all the vital pieces of information about ICD-10 implementation. From understanding coding requirements to familiarizing yourself with CMS’ FAQs on ICD-10 flexibility, here are twelve things you need to know about ICD-10 implementation:

1. Are you ready? PracticeMax can help.

PracticeMax has been hard at work preparing for the transition to ICD-10 by updating systems, training staff, testing with payers, and providing education to our clients. Our dedicated ICD-10 team has been behind the scenes working on end to end implementation, including:

  • System upgrades
  • Payer readiness assessments
  • Comprehensive code set training for our coding and billing staff
  • The evaluation and recommendation of tools to help support your transition to ICD-10

At PracticeMax, we understand the importance and significant efforts involved with ICD-10. Let us help your practice with tools and expertise to successfully transition and beyond. To find out more, please email us at ICD10@practicemax.com.

2. Understand new documentation & coding requirements in ICD-10.

It is critical to fully understand the impact of ICD-10 on your clinical documentation and coding requirements.

  • Identify potential new elements required to code diagnosis for common conditions in ICD-10
  • ICD-10 codes include laterality, anatomic specificity, episode of care, severity and other concepts that provide greater specificity than ICD-10
  • Codes are assigned based on the specific documentation in the patient’s record, so ensure you are capturing all clinically relevant details

3. Crosswalk your top 20-50 codes and/or understand documentation requirements for frequently used codes.

  • Give your providers a sampling of the top relevant codes for your practice and have them crosswalk from ICD-9 to ICD-10
  • Conduct chart reviews and give providers examples that engage them in the ICD-10 process
  • Ensure providers understand the documentation and coding requirements for their top used codes

 4. Secure a line of credit or cash flow savings to help deal with the anticipated temporary drop in revenue with ICD-10.

  • Prepare for a 30-50% temporary delay in revenue for at least three months
  • It is suggested that practices have a minimum of the equivalent of 30 days of operating capital on hand
  • Budget for both monetary and productivity losses

5. Assess your practice’s readiness by taking the PracticeMax ICD-10 Preparedness Survey.

 Answer the following questions for your practice:

  1. Have we evaluated superbill alternatives to accommodate the new ICD-10 code set?
  2. Have we identified our top twenty ICD-9 codes?
  3. Have we identified our physician documentation training needs for our most common patient complaints?
  4. Do we have a plan to implement physician documentation and training?
  5. Have we reviewed and revised/recreated every form that includes diagnostic information?
  6. Have we identified our Lab Documentation training needs?
  7. Have we identified our Diagnostic Imaging documentation training needs?
  8. Did we update our HIPAA privacy policies if they reference ICD-9 codes?
  9. Have we identified all required system updates and how these will impact patient encounters?
  10. Have we identified any prior authorization policies that will change with ICD-10?
  11. Have we updated forms and provided training on the new prior authorization policies?
  12. Have we considered areas within our practice where expense may be impacted by ICD-10 and have budgeted accordingly?

6. Even the CMS Ombudsman thinks the ICD-10 transition will be “rocky.”

CMS Ombudsman, William Rogers, MD understands that physician practices and hospitals are worried about the temporary delay in revenue associated with ICD-10 and acknowledges it will be a “rocky couple of months” after the transition occurs on October 1. Providers can contact Rogers by email at icd10_ombudsman@cms.hhs.gov to report complaints and submit any issues they are experiencing with the new code set.

While Rogers gives the preparedness of CMS systems a “clean bill of health”, a recent Government Accountability Office (GAO) has more of a wait and see attitude. According to a GAO report released on September 10, “While CMS’s actions to update, test, and plan for contingencies can help mitigate risks and minimize impacts of system errors, the extent to which any such errors will affect the agency’s ability to properly process claims cannot be determined until CMS’s systems begin processing ICD-10 codes.”

7. Train, educate and monitor. Repeat.

  • Complete and implement a training plan for your staff including physicians, providers and front and back office employees
  • At PracticeMax, we follow the guidance of the American Academy of Professional Coders (AAPC):
    • For certified coders to be prepared and cognizant for the ICD-10 transition we expect and recommend:
      • AAPC Basic ICD-10 Training (36 hrs) + AAPC Refresher Coding Training (4 hrs) = 40 hours total training hours

8. Identify everything on your practice and office that includes a diagnostic code and update it.

  • Review all lab orders, cheat sheets, other requisitions, policies and procedures, authorization forms and update them with the appropriate ICD-10 codes
  • Essentially, you want to look at all forms, including superbills (if used) currently utilized by your practice and anything coming out into or out of your office
  • You may need to reach out to external vendors and partners to make updates.

9. Practice on your EHR.

  • Update ICD-9 codes to ICD-10 and become familiar with the process.
  • Proactively update codes prior to patient appointment to help streamline the process.

10. Identify resources for ICD-10 code look-ups.

  • There are several resources for code look up and they all vary in their level of features and functionality.
  • A subscription based services with rich features and functionality
    • MyCodingTools
  • Free, basic look up tools
    • World Health Organization
    • ICD-10 Data.com

11. Familiarize yourself with CMS’s FAQs and Guidance on ICD-10 flexibility.

  • On Monday July 27th, CMS issued Guidance on the recent CMS/AMA joint announcement regarding ICD-10 flexibilities. The Guidance comes in the form of a frequently asked questions (FAQs) document.
  • Below we’ve provided important information and highlights from the FAQs we think you’ll want to become familiar with as quickly as possible.
    • If a claim is rejected, Medicare will provide detail whether it is due to:
      • An invalid code
      • Denied for lack of specificity for a National Coverage Determination (NCD) or Local Coverage Determination (LCD)
      • Other claim edit
    • The term “Family of Codes” is the same thing as the Three Character Category:
      • The codes included in each category are “clinically related”
      • The codes capture specific information about the nuances of the condition
      • Be sure to report a code and not a category number
    • The Guidance clarifies that there are still certain circumstances where a claim may be denied because:
      • The ICD-10 code is not consistent with applicable policies
      • The ICD-10 code is not valid (must contain the appropriate number of characters, up to 7)
    • The coding specificity necessary for NCDs and LCDs will not change with the recent CMS/AMA Guidance. Nor will the amount of specificity required for these policies change with ICD-10, with the exception of laterality.
    • It is mandatory for State Medicaid programs to process and pay claims with ICD-10 on or after the deadline (10/1/15) in a “timely manner”.
    • Note that the “flexibility” with regard to Medicare claims processing “does not apply to claims submitted for beneficiaries” with either primary or secondary Medicaid coverage.
    • Providers that don’t submit claims with valid and billable ICD-10 codes will not be provided Federal Matching Funds to offset the cost of denied claims.
    • This Guidance ONLY applies to Medicare. Neither Medicaid nor Commercial payers are mandated to grant flexibility in their claims adjudication for ICD-10.

12. Keep in mind the big picture!

Your practice has undoubtedly been through a lot of stress, change and expense preparing for a successful transition to ICD-10.

Although this deadline may not be as enthusiastically received as other highly anticipated events, keep in mind the benefits ICD-10 will provide for patients and providers:

  • The ability to measure quality, safety and outcomes of care
  • The provision of research, epidemiological studies and clinical trials
  • Data to guide operational and strategic planning for the design of health care delivery systems
  • Monitoring of resource utilization and performance
  • Improvement of clinical, financial and administrative performance
  • Prevention and detection of health care fraud and abuse
  • Ability to track public concerns and assess the risk of adverse public health events_ ______________________________________________________________________________

As you continue to prepare for the ICD-10 transition, it is important to keep these things in mind regarding ICD-10 implementation. If you follow these twelve points, it will make the transition on October 1st much simpler and stress free.