ICD-10 Soon to Be a Reality
By David B. Chauvin, DO, FACEP
CD-10 CM is scheduled to be implemented October 1, 2015. Last year, Congress decided to delay the implementation of ICD 10 CM due to concerns from medical organizations that the change was burdensome and expensive. Most experts agree that any further delay would cause more disruption than any meaningful administrative relief.
Emergency physicians are concerned about the extra time away from direct patient care that will be needed to meet the documentation specificity required by ICD-10 CM. Emergency Physicians believe they are already leveraged to the maximum with the use of scribes, physician extenders, macros and EMR demands, let alone patient satisfaction and providing top quality care. In reality, some ED charts have the required relevant details, but perhaps not in an ICD-10 CM user-friendly format.
ED physicians also fear that using a complicated coding system may lead to mistakes that could trigger reimbursement denials, or worse, expose their practice to fraud and abuse allegations. Smaller and mid-sized emergency groups may not have the cash reserves or credit lines to take a significant hit in reimbursement. Much of the burden will fall onto ED coders. Even with additional training it is anticipated their productivity will decrease due to the additional coding details required by ICD-10.
A recent University of Illinois at Chicago study suggests that emergency department doctors will have reimbursement problems when the ICD-10 codes are implemented. That study can be accessed through the following link:
Study: EDs might have trouble documenting care under ICD-10
The study examined 1,830 ICD-9 codes that are frequently used in the ED and concluded that 27 percent of codes did not easy fit within the ICD-10 framework. In addition, 23% of 24,000 documented ED encounters were at risk for incorrect code assignment under CMS recommendations. This report cites prior studies that show convoluted mappings and information loss in non-ED settings, such as pediatrics and hematology-oncology. The authors conclude that problems due to ICD-10 will be more widespread for independent physician groups than salaried physicians since the former group typically performs their own billing. "ICD-9-CM to ICD-10-CM transition is not straightforward and contains hidden mapping and planning challenges that may have not been accounted for even at this late stage of the sprint toward ICD-10-CM implementation," the report's authors say. "These challenges, if not addressed, may carry significant cost and workflow issues that will be shared by providers and payers alike."
But what about the payers… will they be ready?
In 2014, a handful of private payers announced they would not be ready for the ICD-10 conversion. With the delay in implementation, hopefully this is no longer the case. Regarding Medicare, The Government Accountability Office (GAO) released a report on the readiness of CMS and the health care industry for ICD-10 conversion on October 1, 2015. The report highlights the successful efforts of Medicare to complete ICD-10 related changes and declares that Medicare is ready for ICD-10 CM. http://www.gao.gov/products/GAO-15-255. It is unclear how prepared state Medicaid programs will be. Since a significant percentage of emergency patients are covered by Medicaid, this presents a valid risk to ED groups.
Recently, a bill has been proposed targeting these major concerns; especially that reimbursement will be delayed due to ICD-10 CM implementation. The “Increasing Clarity for Doctors by Transitioning Effectively Now Act” is an attempt to create a safety net for medical claim reimbursements for providers struggling to get ICD-10 coding correct. This bill will provide three potential administrative reliefs.
1) Safe Harbor. During the implementation period, no claim submitted for payment by a health care provider using ICD–10 CM standard medical data code sets would be denied due solely to the use of an unspecified or inaccurate diagnosis code.
2) Assistance. During the implementation period, this bill requires the Secretary of Health to take affirmative steps to assist health care providers in identifying appropriate ICD–10 subcodes.
3) Certification. Require that the Medicare-fee-for service claims processing system based on the ICD–10 standard is fully functioning and would require certification of that fact.
If adopted, the implementation period proposed by this bill would begin October 1, 2015, and last 18 months.
Although the AMA is on record as opposing ICD-10 implementation, as far as CMS is concerned, it's all systems go for October 1 of this year.