ICD-10 delayed, but don’t put off preparations

ICD-10 has been delayed again. We were convinced that the momentum and money supporting the change were too much to stop the train. The old truism, “follow the money” is usually correct. In this case, it was dead wrong. The major groups with much more lobbying power than physicians-the insurance industry and the American Hospital Association, among others-had spent millions of dollars and are prepared for ICD-10.

However, the American Medical Association stayed the course, demanding a delay in implementation of ICD-10, and thanks to the lobbying efforts of that organization as well as physicians in both chambers of Congress, we have a delay.

So with implementation pushed to Oct. 1, 2015, what happens now? In this article, we will discuss what we think you should do next.

In 2012 and 2013, we had recommended that every practice select a champion to learn ICD-10 early. For larger practices, we suggested both a clinical and a technical/business champion. We also suggested that providers should not learn ICD-10 until closer to implementation time.

During the last few months prior to implementation, we had suggested that you concentrate on teaching your providers both codes and documentation, having the remainder of your billing staff learn the ICD-10 codes for your most common procedures, create payer crosswalks, and learn how to use your electronic systems and how they cope with ICD-10.

We had also suggested that you shouldn’t plan to learn ICD-10 with a single seminar; instead, you should have exposure and multiple touches to include educational efforts by your champions in the form of webinars, seminars, and chart audits to determine the appropriate documentation.

The extra time between now and implementation in 2015, combined with our experience in reviewing multiple charts from multiple practices, has led us to alter our recommendations slightly. Below are our current recommendations and somewhat-fluid timetables.

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Revised recommendations, timetables

Plan for the current implementation date. Plan to be prepared for implementation of ICD-10 on Oct. 1, 2015. There will be attempts to delay ICD-10 even further. Also, some have suggested that we skip ICD-10 and go to ICD-11. ICD-11 is less structured and more computerized and will require significant modifications to develop the “CM” (clinical modification) version used by the U.S. ICD-11 is just now being implemented worldwide, and modifying it to fit U.S. needs will take many years. One authority suggested that the different modifications are all building blocks and emphatically stated switching to ICD-11-CM without first using ICD-10-CM would be impossible. Although another delay is possible, we highly recommend that you are fully educated and prepared for implementation of ICD-10 on Oct. 1, 2015.

Select champion(s). Select one, or if possible, two champions (one for clinical and one for technical/business) to first learn ICD-10 and then organize and monitor the entire education and implementation process. Champions should begin immediately to understand the complexities and ramifications of implementing ICD-10.

Do a compatibility check. Double-check with all vendors to be absolutely sure your practice management system, electronic medical records system, and clearinghouses are ICD-10 compatible.

Test the system. Take advantage of all opportunities to submit “test” claims to each of your payers. The previously announced test periods will probably be delayed. However, even if the opportunity arises soon, do not miss an opportunity to test all of your information systems.  Testing dates may be moved due to the delay, test when you have the opportunity.

Set up provider training. Providers should be exposed to the details of the ICD-10 system as soon as possible. However, your system may not provide you with the ability to maintain knowledge if you pursue full training far ahead of the implementation date. For provider training, you will need to implement a strategy that works with your system. The two strategies listed below target the two ends of the spectrum: those groups that are mostly prepared and ready, and groups that have not started training:

• A number of systems are available that will allow you to run ICD-9 and ICD-10 in parallel. For those who are working with these systems, it may be possible to start running ICD-10 today. As this allows teaching and continued use, it is an excellent course of action. With these types of systems, you can slowly educate your providers and make changes to templates throughout the year. In short, keep training on ICD-10.

• Most practices we have spoken with are not this far along and have been waiting to train physicians until the deadline is closer. For those in this category, we recommend revisiting your understanding of ICD-9 and the documentation required for accurate diagnosis coding. In assisting a number of clients with legal audits, ICD-10 preparation, and general educational audits, we have been surprised at how many ICD-9 regulations have been ignored. Luckily, ICD-10 regulations are similar and revisiting ICD-9 will assist in getting ready for ICD-10. With a strong ICD-9 base, ICD-10 implementation will be easier. ICD-10 direct training can be introduced slowly over the year with a strong push for final training beginning in April 2015.

Improve documentation. Start improving your documentation to meet the requirements for ICD-10. More detailed and complete documentation now will improve your billing and collections and protect you from “take backs.” Medical necessity denials are increasing; a focus on ICD-9 and ICD-10 guidelines will help when you are up against some of these denials.

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Don’t forget about ICD-10-PCS. There is a second part to the ICD-10 system: ICD-10-PCS (Procedural Coding System). ICD-10-PCS will be used by hospitals in billing for hospital inpatient claims only. As you are probably aware, hospitals are paid by diagnosis-related groups (DRGs). Assignment of the appropriate DRG requires the principal diagnosis (ICD-10-CM), secondary diagnosis, and procedural codes (ICD-10-PCS). ICD-10-PCS is much more detailed than ICD-9-PCS, which is currently being used.

Your office staff will not have to learn to code by ICD-10-PCS; however, the hospital will not be able to assign the appropriate code without documentation providing them with the appropriate detailed information. The hospital coding staff will likely be forced to track you down for clarification of what was done in the OR if the operative note does not contain the needed detail. A discussion with the hospital may be in order, but a bit more attention to detail in your operative note is a step in the right direction.

Set up a crosswalk. We recommend developing a crosswalk of your top 50 ICD-9 codes to ICD-10. This crosswalk can be used to update your communication sheets (ie, superbills) and templates. This process should be tasked to your in-office champions. There are also firms (including Physician Reimbursement Systems) that can assist you in this process.

The home stretch

Get to know common codes. Approximately 4 to 6 months prior to the start date, the urologist, physician assistants, nurse practitioners, and other clinical staff should work to become familiar with ICD-10 for the most common codes used in your office.

Check compatibility again. Approximately 3 months prior to the start date, all business systems should be double checked for compatibility. This includes sending test claims to all payers.

Establish a working knowledge of ICD-10. On July 1, 2015, urologists, PAs, NPs, and other clinical staff should get their ankles taped and get ready for the sprint to the finish line. This is the time to develop a working knowledge of ICD-10. Do not study crosswalks; learn the new system.

Ensure forms are ready. Approximately 1 month prior to the start date, be sure all templates, communication sheets, superbills, and other forms are in place and ready to use.

Use the new system. On Oct. 1, 2015, flip the switch and start using ICD-10 for all the payers that are required to use it, including those that are not required but have chosen to use ICD-10.

Summary

In summary, the delay has given us a breather and should provide us enough time to be well prepared when the start date arrives. Take advantage of the delay to reach a higher level of preparedness. More complete documentation will improve your bottom line now and is one less thing to learn and to put into place on Oct. 1, 2015. PRS has chosen to continue with current ICD-10 programs that were scheduled for 2014; many other groups have made the same decision. PRS and other groups will also offer training next year in the final push to get ready. Set a plan appropriate for your group and execute.UT

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