MGMA Anticipates Problems, Disruptions With ICD-10: Q&A

MGMA Anticipates Problems, Disruptions With ICD-10In the wake of several dismal surveys and a disturbing Medicare announcement, providers would be forgiven for thinking that ICD-10 is on life support and fading fast. Will the industry be ready by the October 1, 2014 compliance date? If it isn’t, what will we do? EHRintelligence spoke to Robert M. Tennant, MA, Senior Policy Advisor at the Medical Group Management Association (MGMA), to talk about what the future holds for providers, payers, clearinghouses, and coders as ICD-10 creeps ever closer.nn[toggle title_open=”CMS has stated that Medicare won’t be conducting external end-to-end testing with providers. How will that impact the ICD-10 transition?” title_closed=”CMS has stated that Medicare won’t be conducting external end-to-end testing with providers. How will that impact the ICD-10 transition?” hide=”yes” border=”yes” style=”default” excerpt_length=”0″ read_more_text=”Read More” read_less_text=”Read Less” include_excerpt_html=”no”]nnWith the Version 5010 transition, Medicare conducted National Testing Day and other communications like that to encourage testing, which really helped providers meet that particular challenge. Even with that, about half a dozen state Medicaid agencies were not ready for the transition to Version 5010. So you’ve got that as the foundation, and then we find out that Medicare does not plan to test with providers. We believe that is an absolute recipe for disaster. If practices don’t know if a) the claim will even be accepted for adjudication, and b) whether or not the claim will be paid, then there could be real cash flow issues following the compliance date.nnFrom our perspective, just because Medicare itself may be ready to accept ICD-10 claims, that does not guarantee that they will be paying a particular ICD-10 code that shows up on the claim. That’s the reason why we need to test: so providers know well in advance if a particular code is appropriate, and if it’s not appropriate, they will need to be able to change that code or ensure that they have the documentation that supports that code. And you can only do that prior to the compliance date through testing.nnAs we mentioned in our letter to HHS Secretary Kathleen Sebelius, what kind of message does it send to the industry if Medicare itself says they won’t be testing? Does that give a green light to commercial health plans to say they don’t need to test either? That means that when you flip the switch October 1, 2014, providers literally will have no idea if they’re going to be paid for their services.[/toggle]nn[toggle title_open=”Are other health plans going to be conducting external testing?” title_closed=”Are other health plans going to be conducting external testing?” hide=”yes” border=”yes” style=”default” excerpt_length=”0″ read_more_text=”Read More” read_less_text=”Read Less” include_excerpt_html=”no”]nnWe haven’t heard of any health plans that are testing with their providers right now. So we have no idea. But let’s say you have a claim with an ICD-10 code, and you submit that same claim to a hundred payers. You may have a very wide variation on if they pay it, and at what rate, because each will be driven by a proprietary payment policy. Needless to say, we’ve called on health plans to release those payment policies as quickly as possible, so we can understand the variation.nnMany of the large health plans should be ready to test by the first quarter of 2014…or at least that’s what they’re saying publically. But this is a very heavy lift for everybody, including the health plans, because it’s not just a question of reworking their software to accept a different length of diagnostic code. All their payment policies must be examined and rewritten to accommodate the changes in the codes. I think that has proven to be more challenging than many had anticipated.[/toggle]nn[toggle title_open=”What will happen if the industry doesn’t get ready in time?” title_closed=”What will happen if the industry doesn’t get ready in time?” hide=”yes” border=”yes” style=”default” excerpt_length=”0″ read_more_text=”Read More” read_less_text=”Read Less” include_excerpt_html=”no”]nnThe issue of contingency planning is going to be a critical one, and it’s one that MGMA is going to be looking at very closely as we move into 2014. We’re going to be replicating our survey on a regular basis to track the readiness level of the industry. And let’s say that we do a survey in late Summer or early Fall of 2014 to show that trading partners are not ready, I can assure you that we will be communicating a very robust contingency plan to CMS.nnI would not be surprised if dual processing, or in other words, accepting both ICD-9 and ICD-10 codes, would be part of that. We have heard from other health plans that they don’t want to move in that direction because it’s too much work, but we can’t have services not paid for in this country. That would be disastrous for patient care. Just like every other implementation of a HIPAA standard, there have always been delays and contingencies, so I suspect ICD-10 will be no different.[/toggle]nn[toggle title_open=”What are the key issues that might prevent a successful transition?” title_closed=”What are the key issues that might prevent a successful transition?” hide=”yes” border=”yes” style=”default” excerpt_length=”0″ read_more_text=”Read More” read_less_text=”Read Less” include_excerpt_html=”no”]nnOne thing that has not been discussed much is the role of the clearinghouse. A vast majority of our survey respondents say that they send their claims through a clearinghouse. A clearinghouse, however, typically cannot assign an ICD-10 code. Without the clinical documentation in front of them they can’t take an ICD-9 code and just magically convert it to an ICD-10 code. That has got me concerned – especially when the clearinghouses report that 20% of their clients are still running 4010, which cannot accept an ICD-10 code at all. So right away we have an enormous problem.nnThen we have state Medicaid agencies. If a significant number of them weren’t ready for 5010, how many will not be ready for ICD-10? So dual coding may be forced upon the industry because certain health plans, especially on the Medicaid side, may not be ready in time.[/toggle]nn[toggle title_open=”What should providers be doing right now?” title_closed=”What should providers be doing right now?” hide=”yes” border=”yes” style=”default” excerpt_length=”0″ read_more_text=”Read More” read_less_text=”Read Less” include_excerpt_html=”no”]nnPractices have to run on the assumption that their trading partners may not be ready well in advance of the compliance. Practices can still take steps even their software is not yet updated , and testing can’t occur with your clearinghouse or your health plans. They can take a sample of claims that have already been adjudicated successfully and paid and try to assign an ICD-10 code to that claim based on the existing documentation. During the next year, it is a good exercise to say “What would that ICD-10 code be?”nnAnd the other thing to consider is dual coding to become better acquainted to what is required under ICD-10. The practice assigning both ICD-9 and ICD-10 codes at the same time, of course, is made more challenging because we don’t know what is expected from the health plans. However, but if practices assume that unspecified is generally not going to be accepted for payment, then they will need to focus on ensuring that sufficient clinical documentation in included in the patient record so the physician or coder can assign that more specific code. Doing those two things can arm the practice with knowledge of how their physicians are faring with their encounter documentation and alleviate at least some of the stress of October 1, 2014.[/toggle]n

Online ICD-10 specialty-specific provider training modules coming soon!nContact us for more details

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On-site, custom ICD-10 training for staff and providers – book your ICD-10 trainer now!

nSource: www.ehrintelligence.com; Jennifer Bresnick; July 30, 2013.

Aquatic Adventure

Aquatic AdventureS90.871A — Other superficial bite of right foot, initial encounternnW56.01XA — Bitten by dolphin, initial encounternnY93.15 — Activity, underwater diving and snorkelingnnY92.832 — Beach as the place of occurrence of the external cause.nn nnIn preparation for the upcoming deadline for ICD-10 implementation, Welter Healthcare Partners presents weekly ICD-10 Codes of the Week! Our goal is to familiarize you with the new and expanded code set and the additional clinical documentation needed from your providers to comply with ICD-10 coding, and more importantly, for accurate and clean claims submission to keep your revenue stream flowing! We are to help YOU prepare for the October 1, 2014 implementation date. Please don’t hesitate to contact us for all of your training and education needs!

Top Five ICD-10 Readiness Questions To Ask Your Payers

icd-10When all is said and done, ICD-10 is about the money. On October 1, 2014, providers just want to know if they’ll be getting paid for their services. The question isn’t as easy to answer as many people think, and there are plenty of jitters when it comes to how payers will handle ICD-10 codes, if they will be processed in a timely manner – and if the new version of their claims will even go through. Unfortunately, it’s impossible to predict whether the industry will be ready on time, and if the transition will be a success. But even without a crystal ball, you can get a jump on your preparations by asking your payers this list of important questions about their ICD-10 plans.n

Who is my dedicated contact person?

nJust like with vendors, many health plans are big, bureaucratic organizations, and they have just as much on their plate as you do. They will have hundreds or thousands of physicians asking them the same questions about ICD-10, and you don’t want to get lost in the shuffle. Make sure that you have a dedicated point-person to talk to, and that he or she is capable of giving you timely and meaningful answers.n

icd-10Are you going to be conducting external testing?

nWith all the stress that CMS has put on testing, testing, testing, this is still a very important question to ask, because the answer might very well be “no”. Medicare’s official position at the moment is that CMS contractors will not be conducting full external testing with business partners, leaving the vast majority of providers unsure if their claims can be accepted by the biggest payer in the industry. And since many major health plans follow Medicare’s lead, there is widespread concern among providers that they will be left guessing ahead of the implementation date.n

When will you be ready to do so?

nIf some or all of your payers will be conducting testing, be sure to ask when they’re going to be ready to start, how many claims they will want to accept from you, and what kind of feedback you’ll be getting on the quality of your ICD-10 coding. Ensuring that both you and your payer are HIPAA Version 5010 compliant is one of the critical aspects of ICD-10 that hasn’t been stressed enough. ICD-10 is entirely based on 5010, and if you’re one of the providers who haven’t switched over yet, you’re not going to be able to send and receive billing information at all.nnTesting isn’t just a technical necessity. It will also help you figure out if unspecified codes are acceptable to any of your business partners, and if your documentation and medical coders are up to snuff. This extra practice for your staff can help mitigate productivity losses after go-live, and make them more comfortable with the idea that they’re on the right track.n

Will you be dual processing? When will you start?

nMany payers are looking to dual processing – accepting both ICD-9 and ICD-10 codes for a period of time to ease the transition and allow comparisons – as the best way to move forward and keep revenue flowing appropriately. It’s an enormous opportunity for providers, as well: your coders and physicians will have extra time to practice their documentation improvement strategies and ICD-10 coding while seeing exactly what the world after October 1 will look like.n

ICD-10

nWhile CMS has not indicated that dual coding will be accepted for some transition period after October 1, ask your payers if they are planning to take this step, and when they will start so you have the most time to maximize the benefits of side-by-side coding.n

What happens if things go wrong?

nYour payers might not have an answer for you. No one really knows what’s going to happen on October 1, and with a year left on the clock, anything is possible. Thorough, meaningful communication with all your business partners is the best way to ensure that if something does go wrong, you have a contingency plan in place to mitigate the fallout. Both payers and providers stake their entire businesses on making sure that claims are paid quickly, smoothly, and to the fullest extent, so it’s in everyone’s best interests to work together during the crucial time.n

Online ICD-10 specialty-specific provider training modules coming soon!nContact us for more details

n

On-site, custom ICD-10 training for staff and providers – book your ICD-10 trainer now!

nSource: www.ehrintelligence.com; Jennifer Bresnick; July 29, 2013

Is There Anyone Who WOULDN’T Have These Codes Assigned?

Is There Anyone Who WOULDN’T Have These Codes Assigned?Z56.5 – Other physical and mental strain related to worknnZ63.1 – Problems in relationship with in-lawsnnZ62.891 – Sibling rivalrynn nnIn preparation for the upcoming deadline for ICD-10 implementation, Welter Healthcare Partners presents weekly ICD-10 Codes of the Week! Our goal is to familiarize you with the new and expanded code set and the additional clinical documentation needed from your providers to comply with ICD-10 coding, and more importantly, for accurate and clean claims submission to keep your revenue stream flowing! We are to help YOU prepare for the October 1, 2014 implementation date. Please don’t hesitate to contact us for all of your training and education needs!

House Energy and Commerce Health Subcommittee Release SGR Repeal Legislation

House Energy and Commerce Health SubcommitteeHouse Energy and Commerce Health Subcommittee drafts bill to repeal the Medicare sustainable growth rate payment formula

nYesterday evening, the House Energy and Commerce Health Subcommittee began marking up a bipartisan bill to permanently repeal the Medicare sustainable growth rate (SGR) payment formula. The legislation allows for a transition to new performance-based delivery reforms and incentivizes physicians to begin practicing under those models now. The bill provides an annual 0.5% physician payment update for five years through 2018 to create a period of “stability.” In that period CMS will use existing quality measures such as PQRS and the EHR Incentive Program to provide a quality bonus structure,. Physicians may begin practicing under “Alternative Payment Models,” which may pay bonuses based on existing quality measures.nnBeginning in 2019, updates in fee-for-service beyond 0.5% will be dependent on the development of an Update Incentive Program (UIP) based on new quality measures to be developed by provides and the Secretary of HHS. High performing providers will be eligible for a 1% update based on quality measures. Underperforming providers will be subject to a 1% cut in payment. In the interim, providers will have the option of practicing under APMs to promote better care coordination, such as Primary Care Medical Homes, ACOs, and Bundled payments. The bill provides improved access to Medicare data for providers and creates additional avenues for development of new payment and care delivery models.n

Highlights from the Energy and Commerce Draft Framework:

n[vc_toggle title=”Repeal Flawed Medicare Sustainable Growth Rate Formula” size=”sm” el_id=””]For the past decade, Congress had needed to override the SGR formula to undo deep cuts caused by flaws in the formula. This legislation permanently repeals the current Medicare SGR mechanism that places a global cap on Medicare spending on provider services.[/vc_toggle]n[vc_toggle title=”Period of Stability” size=”sm” el_id=””]The legislation provides an annual statutory update of 0.5% per year for 2014 through 2018. During this time, the current law payment incentives, such as the Physician Quality Reporting Program (PQRS) and the Electronic Health Record (EHR) Incentive Program will continue. Quality measure development also will continue to ensure robust availability of measures for rewarding provider performance. Providers will also have the option of using current delivery system reform avenues as well as a new Alternative Payment Models (APM) process to put forward and test new models of care delivery and improvement.[/vc_toggle]n[vc_toggle title=”Rewarding Performance” size=”sm” el_id=””]nnBeginning in 2019, providers will receive an annual update of 0.5%. However, physicians practicing in fee-for-service will receive an additional update adjustment based on quality performance under a new Update Incentive Program (UIP). Performance under the UIP will be assessed based on quality measures and clinical practice improvement activities. These measures and activities may be those currently in use or new measures. Providers and other stakeholders shall be included in the development and selection of measures used in the UIP. Provider performance will be assessed among peer cohorts of like providers providing like services. High performing providers (those that achieve above a threshold) will have the opportunity to earn a 1% bonus payment based on previous performance, while low performing providers (those that are below a threshold) will see a 1% reduction in payments.nnProviders who do not report any quality information will receive the current 2% reduction in payment under PQRS, an additional 3% reduction under UIP. Other incentive programs in title XVIII remain in place.[/vc_toggle]nn nn[vc_toggle title=”Alternative Payment Models (APMs)” size=”sm” el_id=””]Development of new models of care is already underway; many of these new models show great promise for care coordination, keeping people healthy, and encouraging collaboration and shared accountability across the care continuum. This legislation establishes an additional avenue for the development, testing, and approval of APMs beginning in 2015. Under this new process, providers and other stakeholders may submit proposals for new models to an independent entity that will review proposals and make recommendations to the Secretary for models to move forward as either a demonstration or as a permanent program. The independent entity will report at least quarterly on models received and recommendations. Models that are adopted as demonstrations are evaluated by an independent third party for success on improving care or reducing (or not increasing) costs.[/vc_toggle]nn[vc_toggle title=”Supporting Care Coordination and Medical Homes” size=”sm” el_id=””]To support care coordination and development of patient centered medical homes, the legislation establishes new payment codes for complex chronic care management for providers treating individuals with complex chronic conditions. The legislation also ensures that Medicare payment is available for care coordination services performed by physicians who: are certified as a Level III Medical Home by the National Committee on Quality Assurance; are recognized as a patient-centered specialty practice by the National Committee on Quality Assurance; have received equivalent certification; or meet other comparable qualifications.[/vc_toggle]nn[vc_toggle title=”Expanded Data Availability for Care Improvement” size=”sm” el_id=””]To expand the availability of Medicare data for providers to use in developing new models of care and improving quality and patient care, the legislation expands access to Medicare data for certain certified entities. The legislation eliminates the roadblocks that prevented these entities from sharing data directly with providers to facilitate the development of alternative payment models and care improvement.[/vc_toggle]nn[vc_toggle title=”Improving Payment Accuracy” size=”sm” el_id=””]A lack of accurate and meaningful data on costs has hampered the ability of Medicare to review the accuracy of payments for services and identify which services are improperly valued. The legislation would ensure that providers could be compensated for the cost of submitting such data. The legislation also directs Medicare to identify improperly valued services under the fee schedule that would result in a net reduction of 1% of the projected amount of expenditures for a year during 2016 through 2018.[/vc_toggle]nn[vc_toggle title=”Rule of Construction Regarding Standards of Care” size=”sm” el_id=””]This legislation provides that the development, recognition, or implementation of any guideline or other standard under any federal health care provision under the Affordable Care Act, Medicare, and Medicaid shall not be construed to establish the standard of care or duty of care owed by a health care provider to a patient in any medical malpractice or medical product liability action or claim.[/vc_toggle]nnOnline ICD-10 specialty-specific provider training modules coming soon!n

Contact us for more details

n

On-site, custom ICD-10 training for staff and providers – book your ICD-10 trainer now!

nSource: www.fightchronicdisease.com; June 25, 2013.

A Fun Day At The Themepark

A Fun Day At The ThemeparkS13.4XXA — Sprain of ligaments of cervical spine, initial encounter (whiplash injury of cervical spine)nnY93.I1 — Activity, roller coaster ridingnnY92.831 — Amusement park as the place of occurrence of the external cause.nnR11.0 — NauseannIn preparation for the upcoming deadline for ICD-10 implementation, Welter Healthcare Partners presents weekly ICD-10 Codes of the Week! Our goal is to familiarize you with the new and expanded code set and the additional clinical documentation needed from your providers to comply with ICD-10 coding, and more importantly, for accurate and clean claims submission to keep your revenue stream flowing! We are to help YOU prepare for the October 1, 2014 implementation date. Please don’t hesitate to contact us for all of your training and education needs!