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