ICD-10 Grace Period Bills Could Hurt Implementation

ICD-10 Grace Period Bills Could Hurt ImplementationLast week, we reviewed a new bill that would allow for a new two-year “grace period” for accepting the new set of ICD-10CM/PCS code that was presented to the US House of Representatives. Now, we will examine its potential for negative impact on implementation.nnNew legislation that calls for a grace period or transition period to ICD-10 is misguided and could have negative impacts on implementation of the new code set, according to proponents of ICD-10.nnA safe harbor would compromise the ability of Medicare to monitor quality of care, the Coalition for ICD-10 writes in a post on its website.nnThe coalition says recent bills asking for transition or grace periods focus on the assumption that coding in ICD-10 impacts physician payments and will be a burden on providers. These assumptions, the coalition says, are false.nnIn addition, a two-year transition period could be a massive risk when it comes to audits, said Juliet Santos in an opinion piece at ICD-10 Monitor.nnThe comments are in response to a bill proposed by Rep. Gary Palmer (R-Ala.) that would provide a grace period of two years for providers set to transition from ICD-9 to ICD-10 this October. During the grace period, physicians and other providers would not be “penalized for errors, mistakes and malfunctions relating to the transition,” FierceHealthIT previously reported.nnThat’s in addition to legislation brought forth by Rep. Diane Black (R-Tenn.) that would require the Health and Human Services Department to offer end-to-end testing of the code set, as well as an 18-month transition period.nnICD-10 Grace Period Bills Could Hurt ImplementationThese bills, the Coalition for ICD-10 says, could:n

    n

  • Restrict Medicare’s ability to determine coverage, medical necessity and quality of care
  • n

  • Ignore Medicare’s “fiduciary responsibility to ensure proper payment”
  • n

  • Raise fears about the possibility of fraud and abuse
  • n

  • Encourage incomplete documentation
  • n

nSantos adds that if Palmer’s bill is passed, it will void any audit-protective effects of ICD-10.nnThe Centers for Medicare & Medicaid Services “surely cannot afford a bill that condones ‘runaway costs’ through lenient reimbursement strategies at a time when fraud and abuse seem to be so rampant in healthcare,” she says.nnHowever, despite the chance problems could arise from legislation that calls for a transition period, there are some who want to take it even farther–Rep. Ted Poe (R-Texas) recently introduced a bill to Congress that would ban ICD-10 outright.nnThis article originally posted on FierceHealthIT.com.

Bag Fees and Other Administrative Services

Bag Fees and other Administrative ServicesAmerican Airlines, back in 2008, started charging for checked baggage (really, I looked it up!). Up to that point, and even today, most of us have thought that the cost of the ticket should include the cost of checking a bag! As it turns out, the ticket price is only for getting us safely (not even necessarily comfortably) from point A to point B. The rest (food, bags, drinks, in-flight entertainment, etc.) is an up charge.nnIs ambulatory medical care really that much different? The contracted reimbursement rate is for safe, quality and effective medical care. Could everything else (some things) be an up charge? Think about all those administrative services your practice provides to make the health care system work: filling out paperwork, making referral authorizations.nnStay tuned for more Todd’s Tips!nn


nn

Todd150About R. Todd Welter • MS, CPCnFounder and President of Welter Healthcare Partners

nMr. Welter has over 25 years of healthcare industry experience assisting physicians and other providers, hospitals and other facilities with the business side of medicine. Through strategic planning and analysis, Mr. Welter’s main focus is to strategically increase revenues and profitability in this radically changing health care environment. 
Mr. Welter has a Masters Degree in Organizational Leadership from Regis University in Denver where he has had an appointment as affiliate faculty in the School for Professional Studies for over ten years. In addition, Mr. Welter holds a faculty appointment at the University of Denver’s University College. In the Health Care Leadership program he teaches Macro Economics in Health Care and Innovative Strategies and Change in Health Care to graduate students.

The Dangers Of Swimming

The Dangers Of Swimming — Fun With ICD-10T75.1XXA — Swimmer’s crampnnH60.331 — Swimmer’s ear, right earnnB65.3 — Swimmer’s itchnnIn 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, 2015 implementation date. Please don’t hesitate to contact us for all of your training and education needs!

The SGR (Sustainable Growth Rate) Has Been Repealed!

The SGR (Sustainable Growth Rate) Has Been Repealed!The Sustainable Growth Rate (SGR) has been repealed! However, (and there is always a however) it has been replaced with a potentially much more caustic new scheme. The Feds are going to force providers into the quality reporting, clinical practice improvement and EHR MU world. They call it MIPS. Not participating will cost you up to a 9% reduction in Medicare reimbursement by 2022. It’s time to get serious about measuring and improving quality, etc. If you are not on a MU EMR, it’s time! Doing so will potentially get you an additional 9% by 2022.nnStay tuned for more Todd’s Tips!nn


nn

Todd150About R. Todd Welter • MS, CPCnFounder and President of Welter Healthcare Partners

nMr. Welter has over 25 years of healthcare industry experience assisting physicians and other providers, hospitals and other facilities with the business side of medicine. Through strategic planning and analysis, Mr. Welter’s main focus is to strategically increase revenues and profitability in this radically changing health care environment. 
Mr. Welter has a Masters Degree in Organizational Leadership from Regis University in Denver where he has had an appointment as affiliate faculty in the School for Professional Studies for over ten years. In addition, Mr. Welter holds a faculty appointment at the University of Denver’s University College. In the Health Care Leadership program he teaches Macro Economics in Health Care and Innovative Strategies and Change in Health Care to graduate students.

Marine Mammal Mishap

Marine Mammal MishapW56.01XA — Bitten by dolphin, initial encounternW56.12XS — Struck by sea lion, sequelanW56.22XA — Struck by orca, initial encounternW56.31XA — Bitten by other marine mammals, initial encounternnIn 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, 2015 implementation date. Please don’t hesitate to contact us for all of your training and education needs!

US House Introduces ICD-10 Grace Period Bill

US House Introduces ICD-10 Grace Period BillA new two-year “grace period” for accepting the new set of ICD-10CM/PCS codes has been presented in the form of a new bill to the US House of Representatives.nnThe bill, H.R. 2652, Protecting Patients and Physicians Against Coding Act of 2015, was introduced by Representative Gary Palmer (R-AL-6) on June 4.nnThe legislation is the third ICD-10-related bill to be introduced into the House of Representatives in the last five weeks. On May 12, H.R. 2247, the Increasing Clarity for Doctors by Transitioning Effectively Now Act (ICD-TEN Act) was introduced by Rep. Diane Black (R-TN-6) calling for an ICD-10 transition period. On April 30, H.R. 2126, the Cutting Costly Codes Act of 2015, was introduced by Rep. Ted Poe (R-TX-2) seeking to outright stop the replacement of ICD-9 with ICD-10. Neither bill has gained much traction since being introduced. Black’s bill currently has only five cosponsors, and Poe’s bill has nine—much lower than the 46 sponsors this same bill had when Poe first introduced it in 2013.nnH.R.2652 would create a two-year grace period where healthcare providers’ ICD-10-based claims submitted to Medicare and Medicaid would not be denied due to coding errors. Implementing this grace period would ensure physicians are not negatively impacted while ICD-10 is “fully implemented within the healthcare system,” according to a letter sent by Palmer to fellow Congressmen asking for their support of the bill.nnSimilar to the Black bill, H.R. 2652 would not delay the October 1, 2015 implementation deadline for ICD-10 use, but would require the Centers for Medicare and Medicaid Services (CMS) to pay for claims even if inaccurately coded. Palmer states in the letter that this grace period would create a “true transition” to the new code set, and is needed in order to allow physicians “to grow accustomed to ICD-10 over a period of time without being penalized for unintentional errors.”nnshutterstock_114185056During the two-year grace period physicians would not be penalized and their payments would not be withheld by CMS due to “coding errors, mistakes, and/or malfunctions of the system,” according to the bill. The Department of Health and Human Services (HHS) would also be required to conduct a study on how the transition to ICD-10 has affected physicians and other healthcare providers, and state how well HHS has helped physicians transition to the new code set.nnThe bill is needed, Palmer said, because small and rural physicians have not had adequate time or resources to transition to ICD-10, and that learning to do so by October would harm their ability to provide quality patient care and receive proper reimbursement.nnOther healthcare stakeholders have argued that the transition time from ICD-9 to ICD-10 has been ample enough. Also, ICD-10 advocates have pointed out that currently CMS offers numerous resources to help physicians and other providers with the transition, including fact sheets, checklists, guides, timelines, teleconferences, videos, and local training programs, through their Road to ICD-10 website located at www.cms.gov/Medicare/Coding/ICD10/index.html.nn“Although another delay would assist many in the medical community, if ICD-10 is to be implemented on October 1, patient care should not suffer,” Palmer’s letter states.nnThis is not the first time Palmer has tried to stop ICD-10’s outright October 1 implementation. In March he unsuccessfully tried to introduce a delay amendment into the Sustainable Growth Rate replacement bill during the House Rules Committee process.nnH.R. 2652 had 32 co-sponsors as of June 8, and has been referred to the House Committee on Energy and Commerce as well as the Committee on Ways and Means.n

US House Introduces ICD-10 Grace Period BillAHIMA Against H.R. 2652

nAHIMA officials have said they are against this bill since the grace period would lead to inaccurate coding, improper payments, and potential medical billing fraud. With no official repercussions for inaccurate coding, AHIMA officials said they feel it would open the door to both intentional and unintentional coding errors—improperly paid claims at best and rampant fraud at worst—since proper payment of claims depends on accurate coding. Coverage determinations and validation of medical necessity of healthcare services also depend on codes submitted on claims, and would be impacted.nnAlso, claims data are used for many purposes beyond payment, including health policy decisions, assessment of quality of care, patient outcomes and safety, and evaluation of costs. Allowance of miscoding on claims will render claims data useless for any purpose, AHIMA officials said.nnThere are already appropriate mechanisms built into ICD-10-CM for reporting less specific codes when necessary and appropriate. There are “unspecified” codes in both ICD-9 and ICD-10, and unspecified ICD-9 codes are currently already allowed in Medicare fee-for-service payment systems, AHIMA officials said. There is no indication that allowance of unspecified codes will change under ICD-10.nnUS House Introduces ICD-10 Grace Period BillWhile this bill implies that the increase in the number of codes in ICD-10 will cause hardship for physicians trying to find the right code, AHIMA officials counter that physicians and any other medical biller won’t need to learn every ICD-10 code in order to properly bill.nnJust as no healthcare provider uses every code in ICD-9-CM today, physicians and other providers will not use all the codes in ICD-10-CM, AHIMA stated in an ICD-10 FAQ.nnPhysicians should use a subset of codes based on their practice and patient population. “The ICD-10-CM code set is like a dictionary that has thousands of words, but individuals use some words very commonly while other words are never used,” the FAQ states. “Also, laterality accounts for nearly half of the increase in the number of codes in ICD-10-CM–information that is typically already documented in patients’ medical records.nnAHIMA officials have said the grace period is unnecessary since CMS end-to-end testing has shown that only two percent of claims were rejected due to ICD-10 coding errors during the most recent testing period, which ran April 27 to May 1. This is actually lower than the number of claims, 3 percent, currently rejected by CMS after annual ICD-9-CM code updates.nn Welter Healthcare Partners is now listed as an Industry Leader and primary resource for ICD-10 Implementation by United Healthcare, alongside AHIMA ICD-10, AMA, Center for Medicare and Medicaid Services “Road to ICD-10″, HIMSS, and more.n

Click Here To Learn More About ICD-10 Training with Welter Healthcare Partners

n

Click Here To Learn About Our Upcoming ICD-10 Coder Academies

n

Click Here For More Resources from Welter Healthcare Partners

nThis article originally posted on AHIMA.org.