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When it comes to ICD-10 readiness, invest in low-cost, high-impact steps that will benefit the October 2015 switch to new code set, but will also improve the general health of the medical practice.
Now that implementation of ICD-10 has been delayed a full year, "I’d avoid spending too much money at this stage," said Robert Tennant, senior policy advisor at the Medical Group Management Association (MGMA).
Practical steps include checking claims already paid under ICD-9 to see whether the documentation was sufficient to assign an ICD-10 code. In the case of a sprained wrist, for example, make sure the documentation includes whether the injury was to the left or right wrist, Mr. Tennant said.
Robert M. Tennant
Consider dual coding – coding the same claims in both ICD-9 and ICD-10 – for some most commonly used codes, Mr. Tennant advised. If you "go through the clinical documentation improvement exercises, you will produce a better quality medical record and that can help the practice in a number of ways even if ICD-10 never goes forward."
Other low-cost, high-impact steps include reaching out to clearinghouses to request reports on the practice’s top diagnosis codes, the top pended or rejected claims, and the most frequently used unspecified codes.
"That should really focus the practice in on those claims that are the most problematic," he said.
One tough decision is when to upgrade software. Upgrade too early and the practice could lose money if there’s another delay. Wait too long and the practice risks being unprepared for the compliance date, Mr. Tennant said.
He advised finding out when the vendor will be ready with upgrades and how long it will take them to install the software and provide training. Use that to build an implementation timeline.
"It’s such a tightrope that practices have to walk," Mr. Tennant said.
Dallas-based pediatrician Joseph Schneider has been helping physicians prepare for ICD-10 in his role as chair of the Texas Medical Association’s Practice Management Services Council. The association’s official policy is that the move to ICD-10 should be scrapped, but the group is urging physicians and hospitals to prepare anyway.
Dr. Schneider said smaller practices should check in with payers, vendors, and clearinghouses now, but save significant investments and training for next year.
"If you’re in a small physician practice, probably doing not very much between now and December might be a pretty good strategy," he said. "From January forward, you have to start your engines and get everything ready."
But larger practices and health systems don’t have the luxury of waiting, he said.
Dr. George Abraham
Dr. George Abraham, who is part of a six-physician practice in Worcester, Mass., was ready for ICD-10 to take effect this year. His practice spent more than $25,000 preparing for the scheduled switch and had done some initial testing of systems when the delay was announced.
Now the practice faces an additional expenditure on upgrades and refresher courses for coders and physicians.
"After everything, poof, it’s gone in a puff of smoke because everything came to a standstill when ICD-10 got suspended for a year," said Dr. Abraham, governor of the Massachusetts chapter of the American College of Physicians. "It will be déjà vu all over again come summer of next year. We’ll be doing the same thing in preparation for ICD-10 being rolled out in October 2015."
Most health plans won’t begin end-to-end testing of claims until next year, Dr. Abraham said, and that’s worrisome because it may not provide enough time to work out potential glitches.
"A delay in claims being processed is our biggest anxiety," he said. "A delay in payments will lead to a severe cash flow crunch."
Waiting on the CMS for ICD-10 details
Few details have emerged from the Centers for Medicare & Medicaid Services since Congress delayed the implementation of the ICD-10 coding system earlier this year.
As part of Protecting Access to Medicare Act of 2014 (H.R. 4302), Congress delayed implementation of ICD-10 for at least a year. In May, CMS officials announced that the new compliance date would be Oct. 1, 2015, and that physicians and hospitals must continue to use ICD-9 through Sept. 30, 2015.
The agency said it would release an interim final rule in the "near future" with additional details about the compliance date.
Since then, the CMS canceled the end-to-end system testing that had been scheduled for July. The testing will be held sometime in 2015 instead, according to the agency.
But the CMS did report on results of acknowledgement testing conducted with Medicare fee-for-service contractors in March. During the test, providers, suppliers, billing companies, and clearinghouses sent more than 127,000 claims with ICD-10 codes to the Medicare fee-for-service claims system. They received an electronic acknowledgement if their claims were accepted. The exercise did not test whether the claims test had sufficient documentation to be paid by Medicare.