Mark your calendars: Oct. 1, 2013, is the firm date for implementation of the new ICD-10 coding system, a seismic shift in how you'll report your cases and be reimbursed for them. The more detailed ICD-10 descriptions should let you recover more reimbursement for more advanced procedures, but the transition will be costly because it will require new software and more training for coders.
Any claims submitted to Medicare on or after that date won't be accepted unless they use the new codes. There will be no delays, no grace periods. If you're not ready, it's simple: Your claims won't be paid. Although the new codes will not be implemented for another 3 years, you should begin preparing now to avoid potential reimbursement issues.
1. Implement HIPAA Version 5010. Before you can even begin to think about ICD-10, you must first successfully implement 5010 (www.cms.gov/TransactionCodeSetsStands/02_TransactionsandCodeSetsRegulations.asp). Version 5010 is the new version of the X12 standards for HIPAA transactions. The implementation of HIPAA Version 5010 presents considerable changes in the data that you'll submit with your claims, as well as the data available to you in response to your electronic inquiries for eligibility or claims status.
5010 implementation must happen by Jan. 1, 2012. It is a critical element to enable ICD-10 code submission. Contact system vendors early on regarding implementation to ensure that they can support both the legacy and the new coding system and how long that support will be available. This is an ideal time to identify costs for upgrading software and storage capacity as well as contract issues with the vendor. This will help with budgeting in the next several years for the system conversion.
2. Get on your vendor's testing schedule. Even though it may be a few years away, now is the time to ensure the vendor will be able to assist with the transition as well as to schedule the testing and conversion to ICD-10. Vendors will be extremely busy up to 2 years prior to implementation testing and installing new hardware and software for the migration to ICD-10, so getting on the vendor's schedule early on will give you an advantage.
Determine if upgrades are included in the current contract or if there will be additional costs. If they're not included, inquire as to what costs will be incurred. Coordinate with the vendor the timeline for testing and installation of the new or upgraded software and systems. Don't forget training on new systems if you decide to change or upgrade systems. Make sure these costs are included in the budget. If the vendor has user group meetings, it might be an ideal time to participate.
If you haven't already converted to electronic health records or electronic medical records, now might be a good time to do so. If the coding process is currently using a manual system (code books) for coding, you might consider switching to electronic tools such as a code lookup program or encoder when ICD-10 is implemented, which will result in additional software and possibly hardware considerations.
3 Critical ICD-10 Conversations You Must Have |
— Cristina Bentin, CCS-P, CPC-H, CMA Ms. Bentin ([email protected]) is the owner of Coding Compliance Management (www.ccmpro.net), a healthcare consulting company based in Baton Rouge, La. |
3. Perform documentation audits. It's important to make sure the current documentation adequately supports ICD-10. Since ICD-10-CM is more robust and has up to 7 digits of specificity, will your documentation be detailed enough to support ICD-10? You can assess this by conducting medical record documentation audits. Use experienced auditors to conduct audits either internally or externally. Evaluate random samples of records.
It's a good idea to run a practice management report with your top-billed diagnosis codes listed. The need for specificity will increase dramatically. Pull charts based on this report and look to see if any key pieces are missing that would prevent the code from being assigned in ICD-10. If so, begin to work on clinical documentation so that you are compliant and ready to go as of Oct. 1, 2013. In order to assign a code for ICD-10, you'll need to know the episode of care and which knee, for example, was affected.
4. Budget. Depending on the size of your facility, the size of your conversion budget will vary. One fact remains: You must budget for ICD-10 implementation. You'll need to upgrade:
- hardware to accommodate additional space requirements;
- practice management software (ask your software vendors what their ICD-10 plans are);
- financial software (if tied to coding); and
- electronic medical record (if applicable).
You'll also have to account for training requirements and a loss of productivity.
5. Consult your payors. Finally, work with all the health plans that you're contracted with to see what changes may be in store for you, payment-wise. You need to work with provider reps now to see what their plans for implementation are and how they will affect your bottom line.
Don't put it off
Oct. 1, 2013, seems far away, but putting off ICD-10 implementation could really hinder your success. A change of this magnitude in health care has not existed up to this point. Even the implementation of HIPAA pales in comparison with the task ahead of you. It's only careful planning early on that will allow successful ICD-10 implementation.