Posted in ICD-10 & Coding

Now is a good time to panic about the ICD-10 deadline

Carl Natale
by Carl Natale
Now is a good time to panic about the ICD-10 deadline

If you've been ignoring every piece of ICD-10 advice and guidance for the past three years, this is the post you want to read, print out and keep close to your heart.

It's time to get way beyond serious and make ICD-10 happen by Oct. 1. Maybe there will be some sort of grace period or safe harbor. But the expectation is that healthcare providers will need to use ICD-10 codes.

The Centers for Medicare and Medicaid Services (CMS) has a quick start ICD-10 guide for procrastinating physician practices that's worth downloading.

Here's what it covers:

Make a plan

  • Assign target dates for completing steps outlined here
  • Most important, obtain access to ICD-10 codes. The codes are available from many sources and in many formats:
    • Code books
    • CD/DVD and other digital media
    • Online (e.g., go to and select “2016 ICD-10-CM and GEMS” to download 2016 Code Tables and Index)
    • Practice management systems
    • Electronic health record (EHR) products
    • Smartphone apps
  • Decide role(s) your clearinghouse(s) will play in your transition. Some providers who are not ready could benefit from contracting with a clearinghouse to submit claims:
    • Clearinghouses can help by:
      • Identifying problems that lead to claims being rejected
      • Providing guidance about how to fix rejected claims (e.g., more or different data need to be included)
    • Clearinghouses cannot help you code in ICD-10 codes unless they offer third-party billing/coding services


  • You must use:
    • ICD-10 codes for all services provided on or after October 1
    • ICD-9 codes for all services provided before October 1
  • Identify everywhere in your practice that you use ICD-9 codes to make sure you know what processes and systems need to be updated for ICD-10; for example:
    • Patient registration and scheduling
    • Clinical documentation/health records
    • Referrals and authorizations
    • Order entry
    • Coding
    • Billing
    • Reporting and analysis
  • Even clearinghouses that offer coding and billing services cannot translate ICD-9 codes to ICD-10 codes unless they have the detailed clinical documentation required to select the right code
  • Practices that do not prepare for ICD-10 risk disruptions in cash flow
  • For a more in-depth approach to planning, see the Action Plan section of the Road to 10.

Train your staff

  • Train staff on ICD-10 fundamentals using the wealth of free resources from CMS, which include the ICD-10 website, Road to 10, Email Updates, National Provider Calls, and webinars. Free resources are also available from:
    • Medical societies, health care professional associations
    • Hospitals, health systems, health plans, vendors
  • Identify top codes. What ICD-9 diagnosis codes does your practice see most often? Target the top 25 to start. You might want to look at common diagnosis codes available from:
    • Road to 10 (see Specialty References)
    • Medical specialty societies
    • Using the documentation available, code current cases in ICD-10. Flag any cases where more documentation is needed.


  • Training for clinical staff—e.g., physicians, nurse practitioners, physician assistants, registered nurses—should focus on documentation, new coding concepts captured in ICD-10
  • Training for coding and administrative staff—e.g., coders, billers, practice managers—should focus on ICD-10 fundamentals
  • You can review your superbills, encounter forms, and practice management system reports to identify your most commonly used ICD-10 codes
  • If time permits, expand your ICD-10 coding of current cases to include 50 or more of your top codes, until 80% of your claims are covered
  • You don’t have to use 68,000 codes—as you do now, your practice will likely use a very small subset of ICD-10 codes
  • You will use a similar process to look up ICD-10 codes that you use with ICD-9
  • While crosswalks from ICD-9 to ICD-10 can be useful references, ICD-10 codes should be based on the clinical documentation rather than selected from a crosswalk
  • Practices that do not prepare for ICD-10 will not be able to submit claims for services performed on or after Oct, 1, 2015.

Update your processes

  • It is crucial to update hard-copy and electronic forms (e.g., superbills, CMS 1500 forms )
  • Resolve any documentation gaps identified while coding top diagnoses in ICD-10
  • Make sure clinical documentation captures key new coding concepts:
    • Laterality—or left versus right
    • Initial or subsequent encounter for injuries
    • Trimester of pregnancy
    • Details about diabetes and related complications
    • Types of fractures


  • Create a documentation checklist for any new concepts that need to be captured for ICD-10 coding
  • Remember that ICD-10 does not change the requirements for good documentation, which is always about capturing the complete clinical picture in order to provide high-quality patient care
  • Review NCDs and LCDs with ICD-10 codes to ensure consistency with internal policies (e.g., coding, billing, and documentation processes)
  • Outpatient and office procedure codes aren’t changing—ICD-10 does not affect the use of CPT and HCPCS coding for outpatient and office procedures

Talk to Your Vendors and Health Plans

  • Call your vendors to confirm the ICD-10 readiness of your practice’s systems
  • Confirm that the health plans, clearinghouses, and third-party billing services you work with are ICD-10 ready
  • Ask vendors, health plans, clearinghouses, and third-party billers about testing opportunities


  • You can use forms available in the Road to 10’s Template Library to guide discussions with vendors, health plans, clearinghouses, and billing services
  • Double check that you’ve identified all systems that use ICD codes—e.g., practice management systems, electronic health record (EHR) products—when contacting vendors
  • Update contracts with vendors and health plans as needed
  • Transition costs for small medical practices could be substantially lower than projected earlier:
    • Many EHR vendors are including ICD-10 in their systems or upgrades—at little or no cost to their customers
    • Software and systems costs for ICD-10 could be minimal for many providers

Test Your Systems and Processes

  • Verify that you can use your ICD-10-ready systems to:
    • Generate a claim
    • Perform eligibility and benefits verification
    • Schedule an office visit
    • Schedule an outpatient procedure
    • Prepare to submit quality data
    • Update a patient’s history and problems
    • Code a patient encounter
  • Test your systems with partners like vendors, clearinghouses, billing services, and health plans; focus on those partners that you work with most often
    • Medicare providers can conduct acknowledgement testing with their Medicare Administrative Contractors (MACs) until the October 1 compliance date
  • Explore alternate ways to submit claims to health plans if you think your systems will not be ready for ICD-10 by Oct 1:
    • For Medicare providers, options include:
    • Ask other health plans you work with about the options they offer


  • Your clearinghouses and billing services can conduct Medicare acknowledgement testing on your behalf
  • Many major health plans report that they have portals or other options in place for providers who cannot submit ICD-10 claims electronically
  • If you think you might need to use an alternate claims submission method for Medicare, get started now
    • Allow time for you and your staff to complete free training on billing software or portals before October 1
    • You must register for each MAC portal that you use
  • If you are eligible to submit paper claims for Medicare and wish to do so, order CMS 1500 forms from the Government Publishing Office or your office supply store
    • Photocopies cannot be used because they cannot be scanned correctly

There it is. What you need to do before Oct. 1. What are you waiting for? Get to it!