ICD-10 Testing: Final rule overshadows CMS testing plans
Or at least until the federal government changes its mind. And Jim Hennessy, CEO of e4 Services, predicts that U.S. healthcare is doomed to reset the ICD-10 deadline again. His solution is to allow a voluntary ICD-10 implementation date to win the hearts and minds of a "subset of the physician community that was not sufficiently motivated by the incentives associated with HITECH and Meaningful Use to implement compliant EMR systems within their practice operations."
He concedes complexity in his solution. Others would call it chaos.
But maybe healthcare payers would start penalizing ICD-9 claims.
I'm not sure that's a good "hearts-and-minds" strategy. It certainly would be a good testing and ease-your-practice-into-implementation strategy.
Speaking of testing
Perhaps more importantly, the Centers for Medicare and Medicaid Services announced ICD-10 testing opportunities for Medicare fee-for-service providers Friday.
It's going to continue ICD-10 acknowledgement testing. That's when your Medicare Administrative Contractor (MAC) will accept your test claim and let you know if it works. No feedback on whether you used the correct ICD-10 code or not. Nor will you find out how much it's worth.
CMS says it plans acknowledgement testing weeks in November, March and June 2015. Also, it will accept ICD-10 test claims for acknowledgement testing at any time.
Now if you're looking for end-to-end testing, CMS says it has plans for that in January, April and July 2015. Testing goals are:
- Providers and submitters are able to successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems.
- CMS software changes made to support ICD-10 result in appropriately adjudicated claims.
- Accurate Remittance Advices are produced.
More information is coming.
Hospitals are struggling to meet all the mandates in place so outsourcing ICD1-0 expertise makes a lot of sense.
"We still operate in an ICD-9 world, complicated by EHR implementations, value-based reimbursement models, compliance issues and optimizing reimbursement; a perfect storm from which outsourcers have the expertise to shield their clients."
They tend to contract:
- Medical coding
- Clinical documentation services and audits
P.J. Parmar is a family doctor at Ardas Family Medicine who has about 20 ICD-9 codes memorized. They are broad enough to cover most of his work, but a few times each week he needs to look something up.
And this works very well for him.
"Doctors are putting a lot of effort into opposing it; you can’t read about medical policy these days without seeing worries about ICD-10.
"I am not worrying. I suspect I will have to memorize a different set of 20 codes. When I see a patient who got injured in a spacecraft explosion, you better believe I am going to use M79.609, “pain in unspecified limb”, unless my bills stop getting paid. And if they do, I will learn incrementally more codes to barely get by, but you will never find me looking up one of 68,000 codes, 50 times a day."
- Training physicians: "Physicians need to be educated from a clinical perspective — not a coding perspective — because the minute you start showing them codes they will tune out."
- Forms will need to handle longer codes: "You need to get a very good inventory of which forms are being used now with ICD-9 and focus on redesigning them."
- Take care of your people: "It’s important to note that without the right people in place — and those people fully behind the effort — all the tips and tricks, all the system intelligence, and all the hard work and money on the planet could result in a botched or less-than-ideal implementation."
An anonymous blogger wants to know why there's such a big difference between the cost of ICD-10 implementation and the estimated cost of a 1-year delay:
- The original estimate is from 2009 — which has been revised upwards.
- The $6.85 billion is cited at the top end of a range. I could be quite a bit less.
- Dr Anonymous calls it "petty." I call it politics. Which isn't any better. But I would be shocked (SHOCKED!) to find out that political entities are exaggerating costs in their arguments.
- Identify clinical documentation improvement needs
- Offer feedback on documentation
- Monitor documentation and continue feedback after deadline
- "ICD-9 isn't so bad, really."
- "The huge profusion in ICD-10 codes means it will be more difficult to use."
- "Why not just use SNOMED CT or move right ICD-11 instead? They're just as good."