Preparing for ICD-10:
What You Should Be Doing Now
PHCA
November 11, 2014
Presented by: Reinsel Kuntz Lesher LLP Senior Living Services Consulting
Stephanie Kessler, Partner Karin Sherman, Senior Consultant
Timeline
1979
• ICD-9 was introduced 1990
• ICD-10 was endorsed by The World Health Assembly 1995-96
• The UK & France implemented ICD-10 1998
• Australia transitioned to ICD-10 2001
• Canada moved to ICD-10 2015
• United States scheduled to implement ICD-10
Preparing for ICD-10
Implementation of the International Classification of Diseases, 10th Edition, Clinical Modification and Procedure Coding System (ICD-10-CM/ICD-10-PCS) within the United States health care industry from ICD-9-CM for medical diagnosis and inpatient hospital procedure coding is scheduled for October 1, 2015.
The ICD-10-related implementation date of October 1, 2015, was announced in final rule published in the federal register on August 4, 2014. This final rule is available at http://www.gpo.gov/fdsys/pkg/FR-2014-08-04/pdf/2014-18347.pdf.
Preparing for ICD-10
Are you ready??Preparing for ICD-10
• Who is effected by ICD-10-CM implementation?
• On October 1, 2015 medical coding in U.S. health care settings will change from ICD-9-CM to ICD-10-CM.
• The transition requires businesses and systems to change throughout the health care industry.
• Everyone who is covered by the Health Insurance Portability and Accountability Act (HIPAA) must make the transition, not just those who submit Medicare or Medicaid claims.
Preparing for ICD-10
• The compliance dates are firm?
• Prepare now and avoid potential reimbursement issues for services received 10/1/2015 and later.
• There is no impact on Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes.
Preparing for ICD-10
• Partial code freeze• October 1, 2011 – The last regular, annual updates were made to both code sets.
• October 1, 2012 through October 1, 2014 – Only limited code updates for new technologies and new diseases were made to both code sets (Section 503(a) of Public Law 108-173).
• October 1, 2015 – Only limited code updates for new technologies and new diseases will be made to the ICD-10 code set. No further updates will be made to ICD-9-CM on or after October 1, 2015, as it will no longer be used for reporting.
• October 1, 2016 – Regular updates to ICD-10 will start.
Differences between ICD-9-CM and
ICD-10-CM
• ICD-9-CM has approximately 14,000 diagnosis codes and ICD-10-CM will have approximately 70,000 diagnosis codes
• ICD-10-CM codes are longer and use more alpha character to provide greater clinical detail and specificity when describing the diagnosis
• Terminology and disease classification have been updated to be consistent with current clinical practice.
Differences between ICD-9-CM and
ICD-10-CM
• Benefits of ICD-10-CM coding will provide better data to:
• Measure the quality and efficiency of care
• Support operational and strategic planning
• Monitor resource utilization
• Improve clinical, financial, and administrative performance
Differences between ICD-9-CM and
ICD-10-CM
Project Planning
ICD-10-CM Project Planning
• Administration needs to be involved in planning this transition.• Determine who currently utilize ICD-9-CM codes. • Who should be involved in training for ICD-10-CM?
•“C” Suite •Management
•Health Information Management staff •Nursing
•Unit Secretaries •MDS Coordinators/RNACs •Admissions
•Billing
•Rehabilitation Department, Medical Directors, Vendors, etc., etc.
ICD-10-CM Project Planning
• The project planning will be different at each facility
• If you have not already, start now
• There is no crosswalk
• Step 1 – Task Force
• Step 2 – Budget
• Step 3 – Educate
• Step 4 – Implement and Test
• Step 5 - Transition
ICD-10-CM Project Planning
• Considerations • EHR • Paper chart • Vendors • Billing • Physicians
• The Task Force may have subcommittees to ensure all areas are covered and on track
• Budget for education, re-education, orientation, materials costs (i.e., manuals, new forms), and potential delays in claims processing
ICD-10-CM Project Planning
• Determine education needed by determining those who assign or are involved currently with ICD-9-CM codes
• Consider basic versus in-depth training
• Develop a timeline to ensure adequate preparation
• Contact your software vendor to determine:
• When their upgrades will be completed
ICD-10-CM Project Planning
• Project any possible MDS and/or billing backlogs in advance and work to gain compliance prior to October 1, 2015
• Determine additional staff that will be required to maintain a current status through the 10/1/2015 implementation date
Implementation
ICD-10-CM Implementation
• Possible consequences of delays
• Decreased accuracy and productivity of staff related to ICD-10-CM coding
• Increased risk of claims rejection and lack of payments
• Decreased time with patients and impact on patient care
• Decline in staff morale
ICD-10-CM Implementation
• Assess current coders strength and weaknesses to determine training requirements;
• Consider need for refresher courses in anatomy and physiology, medical terminology and pharmacology before starting the ICD-10-CM training due to level of specificity of ICD-10-CM codes.
• AHIMA recommends from 10–36 hours of ICD-10-CM training depending on the experience and
credentialing of the person completing the coding.
ICD-10-CM Implementation
• Testing – November 17-21, 2014
• This testing week will give trading partners access to the Medicare Administrative Contractor’s (MACs) and Common Electronic Data Interchange (CEDI) for testing with real-time help desk support. The event will be conducted virtually.
• What you can expect during testing:
•Test claims with ICD-10 codes must be submitted with current dates of service (i.e. October 1, 2014 through November 17, 2014), since testing does not support future dated claims.
ICD-10-CM Implementation
• Testing – November 17-21, 2014 (cont’d)
• What you can expect during testing:
•Test claims will be subject to all existing EDI front-end edits including Submitter authentication and NPI validation.
•Test claims will receive the 277CA or 999 acknowledgement as appropriate, to confirm that the claim was accepted or rejected in the system.
•Testing will not confirm claim payment or produce remittance advice.
•MACs and CEDI will be staffed to handle increased call volume during this week.
ICD-10-CM Implementation
• ICD-10 Limited End-to-End Testing with Submitters for 2015
• On January 26-30, 2015, CMS will offer end-to-end testing to a small sample group of providers. End-to-end testing includes the submission of test claims to CMS with ICD-10 codes and the provider's receipt of a Remittance Advice (RA) that explains the adjudication of the claims. The goal of this testing is to demonstrate that:
•Providers or submitters are able to successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems;
ICD-10-CM Implementation
• ICD-10 Limited End-to-End Testing with Submitters for 2015•CMS software changes made to support ICD-10 result in appropriately adjudicated claims (based on the pricing data used for testing purposes); and
•Accurate RAs are produced.
• The sample will be selected from providers, suppliers, and other submitters who volunteered to participate. Registration for the January week of end to end testing is now closed. Providers will still be able to send test cases through traditional testing even if not chosen for end to end testing. More information will be sent out if you are selected once the registration forms are reviewed.
ICD-10-CM Implementation
• Training: January through March 2015 (cont’d)• Assess quality of current clinical documentation by physicians and staff to identify improvement opportunities;
•Complete review of random sample of charts; •Focus on high volume diagnoses; and
•Identify diagnoses known to cause documentation problems.
• Determine best solution to improve documentation; •Modify any forms or templates utilized for
documentation both manual and EHR; and •Provide educational opportunities addressing
documentation requirements.
ICD-10-CM Implementation
• Training: January through June 2015 (cont’d)
• Provide training for all staff that utilize the ICD-10-CM codes.
•ICD-10-CM training is available from professional associations, commercial vendors, and
independent consultants
•ICD-10-CM training can be accomplished with line self-paced or instructor-led courses and/or on-site or off-on-site face to face training
ICD-10-CM Implementation
• Training: January through June 2015 (cont’d)• Follow training with hands on practice
•Determine if those individuals who code utilize a list of frequently seen ICD-9-CM codes and convert the codes on the list to have corresponding ICD-10-CM codes, when possible.
• Transitioning from ICD-9-CM to ICD-10-CM: January through June 2015
• Improved documentation will now allow for more in depth ICD-9-CM coding similar to what will be utilized in ICD-10-CM, allowing both practice for the person coding and ease of transition in the future.
ICD-10-CM Implementation
• Transitioning from ICD-9-CM to ICD-10-CM: January through June 2015 (cont’d)
• Print or copy current long term residents’ diagnosis lists and add the ICD-10-CM diagnoses to this sheet.
•Divide the long term population by the 13 weeks in this time period and practice coding that number of diagnosis sheets each week;
•Save the residents’ diagnosis lists with ICD-10-CM codes to utilize when dual coding is available by your software provider.
ICD-10-CM Implementation
• Transitioning from ICD-9-CM to ICD-10-CM: January through June 2015 (cont’d)
• Contact your software provider to determine a date when (or if) dual coding capability will be available to begin data entry.
• The key to this time period is to continue practicing and becoming familiar with looking up and identifying the correct ICD-10-CM code to utilize
ICD-10-CM Implementation
• Transitioning from ICD-9-CM to ICD-10-CM: January throughJune 2015 (cont’d)
• General Equivalence Mappings (GEMs) are designed to help with mapping links concepts in two code sets without consideration of resident clinical record information only and will not take place of individually coding each resident appropriately with ICD-10-CM codes
• ICD-10-CM books are available from existing ICD-9-CM code book publishers.
• ICD-10-CM is available free of charge in PDF and XML formats from:
ICD-10-CM Implementation
• Transitioning from ICD-9-CM to ICD-10-CM: July throughSeptember 2015
• Verify that dual coding capacity is working and ready to use. • Continue dual coding of both ICD-9-CM and ICD-10-CM for:
•New Admissions; •Hospital Returns;
•Long term residents - follow the MDS ARD schedule to code ICD-10-CM codes as assessments are due, utilizing the diagnosis lists that were saved from practice coding last quarter until all diagnosis lists are updated.
ICD-10-CM Implementation
• Transitioning from ICD-9-CM to ICD-10-CM: October 1, 2015 and Beyond
• Utilize ICD-10-CM codes only for all diagnoses for dates of service/admissions starting October 1, 2015 and utilize in medical record documentation and billing.
• Maintain the ICD-9-CM Diagnosis list for verification if any claim denials occur.
ICD-10-CM Implementation
• Transitioning from ICD-9-CM to ICD-10-CM: Billing Claims
• All claims submitted for services on or before 9/30/2015 will use ICD-9-CM;
• All claims submitted for services on or after 10/1/2015 will use ICD-10-CM;
• Claims cannot contain both ICD-9-CM and ICD-10-CM codes
• Claims for services 10/1/2015 and after with ICD-9-CM codes will be REJECTED.
ICD-10-CM Implementation
• Physician education is very important • Documentation is crucial for accurate coding
Other Areas
ICD-10-CM Other Areas
• Additional areas impacted by ICD-10-CM coding:
• Survey
• Minimum Data Set, version 3 – MDS 3.0
•Section I – Active Diagnoses
• Quality Measures
•Pressure ulcers
•Falls
Code Features
ICD-10-CM Code Features
• ICD-10-CM diagnosis codes are three to seven characters;
• The first character is always alpha (all letters except U are used);
• The second character is numeric;
• Characters 3-7 are either alpha or numeric
• A decimal is placed after the third character.
• Example: A69.21 Meningitis due to Lyme disease
ICD-10-CM Code Features
• ICD-10-CM codes have laterality (left, right, bilateral)
• Example: L89.022 •L89.xxx – Pressure ulcer •xxx.02x - Left elbow •xxx.xx2 - Stage II
• ICD-10-CM codes have combinations codes certain conditions with common associated symptoms and manifestations
• Example: I25.110 – Atherosclerotic heart disease of native coronary artery with unstable angina pectoris
ICD-10-CM Code Features
• ICD-10-CM codes may have a character “x” used as a 5th character placeholder in certain 6 character codes allowing for future expansion of the code and to fill in other empty characters when a code is less than 6 characters in length requires a 7th character.
• Example: T46.1x5A – Adverse effect of calcium-channel blockers, initial encounter
ICD-10-CM Code Features
• ICD-10-CM coding may utilize “Excludes” notes:• Excludes 1 – indicates a code that should never be used with the code where the note is located (do not report both codes).
•Example: Q03 – Congenital hydrocephalus (Excludes 1:acquired hydrocephalus (G91.-)
• Excludes 2 – indicates that the condition excluded is not part of the condition represented by the code, but a patient may have both conditions at the same time, in which case both codes can be reported to capture both conditions.
•Example: L27.2 – Dermatitis due to ingested food (Excludes 2: Dermatitis due to food in contact with skin (L23.6, L24.6, L25.4)
ICD-10-CM Code Features
• ICD -10-CM coding includes clinical concepts (did not exist inICD-9-CM.)
• Example: T45.526D – Under-dosing of antithrombotic drugs, subsequent encounter
• ICD-10-CM significantly expands a number of codes. • Example: E10.610 – Type 1 diabetes mellitus with diabetic
neuropathic arthropathy
• ICD -10-CM makes distinction between intra-operative complications and post-procedural disorders.
• Example: D78.21 – Post-procedural hemorrhage and hematoma of spleen following a procedure on the spleen vs. D78.01 – Intra-operative hemorrhage and hematoma of spleen complicating a procedure of the spleen.
ICD-10-CM Code Features
• ICD-10-CM coding includes a 7th character in certain situations. Post acute care providers will most frequently utilize this when coding: injury, musculoskeletal and external cause codes.
• The seventh character describes encounters: initial, subsequent, and sequela (previously late effect in ICD-9-CM).
ICD-10-CM Code Features
• ICD-9-CM Codes• 820.8 – Closed fracture of unspecified part of neck of femur
• V54.13 – Aftercare for healing traumatic fracture of hip • ICD-10-CM Codes
• S72.114A – Nondisplaced fracture of greater trochanter of right femur, initial encounter for closed fracture • S72.114D – Nondisplaced fracture of greater trochanter
of right femur, subsequent encounter for closed fracture with routine healing
ICD-10-CM Code Features
• Additional changes in ICD-10-CM coding:
• Injuries are grouped by anatomical site not type of injury;
• Some new code definitions to reflect current medical knowledge;
• Restructuring and reorganization of disease classification reflecting current medical knowledge; and
• V codes or E codes, as in ICD-9-CM, are incorporated into main classifications.
ICD-10-CM Code Features
• Nonspecific codes (“unspecified” or “not otherwise specified”) are available to use when detailed documentation to support more specific coding is not available.
• A few other coding features are encompassed in ICD-10-CM coding that post acute care settings will most likely not encounter.
• ICD-10-CM coding book continues with an alphabetic index and a tabular index as ICD-9-CM was divided.
• ICD-10-CM codes should be looked up in the alphabetic index and then verified in the tabular index.
ICD-10-CM Code Features
ICD-10-CM Code Features
• An Introduction to ICD-10 fact sheet is available on the CMS website at www.cms.gov/ICD10.
Take Away
Task Force + Needs Assessment + Education + Implementation + Execution = Smooth Transition
ICD-10-CM Implementation
ICD-10-CM Implementation
• Resources include: • www.cms.gov/ICD10 • www.ahima.org/icd10RKL ICD-10-CM Education
SAVE THE DATE
March 10-11, 2015
York, PA
Contacts
Karin Sherman Senior Consultant Reinsel Kuntz Lesher LLP [email protected] http://www.rklcpa.com/industries/senior-living-providers/
Stephanie Kessler Partner Reinsel Kuntz Lesher LLP