ICD-10 Readiness: Making the Transition by the October 1 Deadline

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Posted By: Carol Flagg July 22, 2015

On July 6, 2015, the Centers for Medicare & Medicaid Services (CMS) and the American Medical Association (AMA) announced joint efforts to continue to help providers prepare for the October 1 deadline for transitioning to ICD-10. In the announcement, CMS stated additional guidance will be given to allow for some flexibility in the claims auditing and quality reporting process as providers gain experience in use of the ICD- 10 code set.

The move confirmed the approaching deadline will not be delayed and both CMS and the AMA are providing ample resources to help make the transition. You can read the announcement here.

Last week we hosted a webinar on ICD-10 readiness. Presented by Jim Daley, Health IT Director of BlueCross BlueShield of South Carolina and co-chair the WEDI ICD-10 workgroup, the event attracted nearly 800 registrants.

On the webinar, Jim gave the audience some insights into the results of a WEDI survey conducted in June on ICD-10 readiness. Key findings from respondents to the survey include:

  • Three quarters of vendors said their products were already available. All planned to be complete by 10/1
  • About three quarters of health plans had started or completed external testing. Only two plans indicated potential difficulty in being ready on 10/1
  • Only one hospital/health system responded they wouldn’t be ready by the compliance date, but almost one quarter of physicians said they wouldn’t be ready.
  • Almost three quarters of hospitals/health systems had started or completed external testing, compared to just over one fifth of physicians

Jim’s presentation also looked at:

  • Regulatory Timelines
  • Cost Considerations and calculations
  • Importance of ICD-10 Testing
  • What to do NOW

You can view the YouTube recording of the webinar here. You can download a PDF of the slide deck here.

We left time on the presentation for some Q&A and what follows is Jim’s follow-up on some of the questions asked.

Q: What are the implications of CMS accepting both code sets for 1 year?
A:  CMS is not accepting both code sets for a given date of service. This is a common misperception about the announcement.  The announcement didn’t change the HIPAA regulation that requires use of ICD-10-CM codes for dates of service or for hospital discharges on or after October 1, 2015 and ICD-10-PCS for inpatient procedure reporting.  The CMS guidance clearly stated that ‘the Medicare claims processing systems will not have the capability to accept ICD-9 codes for dates of services after September 30, 2015, nor will they be able to accept claims for both ICD-9 and ICD-10 codes.’

Q: What did CMS mean by family of codes that was mentioned in their FAQ last week?
A: CMS plans to issue guidance as to what was meant.  ‘Family’ is not a recognized term used in coding.   Industry thinking is that although it may mean a less specific code might be accepted by Medicare, the code must be a billable code or issues will arise.

Q:  Is there any indication yet if Medicaid and other private insurance carriers are going to be asked to follow suit with CMS guidance of accepting less specific codes?
A:  The CMS guidance only covered what CMS was planning for items billed under the Part B physician fee schedule. It was not a change to the HIPAA regulations.  Specificity requirements for other payers would be determined by those payers.  At this late date it is unlikely any significant changes would be made to applications prior to the cutover.

Q: You are talking about procedure codes changing with ICD-10.  But you’re talking hospital, correct?  CPT codes will still be used in physician offices? This is the first I’ve heard of 2 sets of codes ICD10 Diagnosis and ICD10 Procedure. 
A: The CMS announcement did not change the requirements in Subpart J of the HIPAA regulation.  ICD-10-CM diagnosis codes are to be used as of the compliance date for both inpatient and outpatient services to report diagnosis.  For inpatient services ICD-10-PCS codes will be used to report procedures.  For outpatient/physician services CPT codes will continue to be used to report procedures.  Additional information regarding Medicare billing may be found on the CMS web site.

Q: What are the implications of CMS accepting both code sets for 1 year?
A:  CMS is not accepting both code sets for a given date of service. This is a common misperception about the announcement.  The announcement didn’t change the HIPAA regulation that requires use of ICD-10-CM codes for dates of service or for hospital discharges on or after October 1, 2015 and ICD-10-PCS for inpatient procedure reporting.  The CMS guidance clearly stated that ‘the Medicare claims processing systems will not have the capability to accept ICD-9 codes for dates of services after September 30, 2015, nor will they be able to accept claims for both ICD-9 and ICD-10 codes.’

Q: Where is the WEDI list for state by state adoption of ICD-10 with workers comp?
A:   The list can be found on the WEDI web site under the ‘Workgroups’ tab and the ‘Transactions & Code Sets’ drop-down selection.   There will be an entry for ‘Property & Casualty Electronic Medical Bill’.  The spreadsheet link is located on that landing page.

Q: Will CMS or any entity identify payers that will not be ready for compliance by 10/1 for ICD-10 codes?
A:  There hasn’t been any announcement about this information being compiled.  One way to assess a payer’s readiness is to look for industry test results for that payer or by direct communication, assuming the payer is willing to disclose that it would not be ready.

Q: Do you recommend buying conversion cards for provider use or wait for an app to get them free?
A:  There are many resources available from industry organizations as well as free information on the CMS web site.  Some resources are free, others are low-cost.  Each entity must decide what best suits their need.

ICD-10 Resources

Here’s a rundown of other various resources: