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Doctors shift focus to compliance as ICD-10 deadline set

Physicians win a one-year reprieve on upgrading to the more complex code sets as the administration finalizes a delay to October 2014.

By — Posted Sept. 10, 2012

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Now that organized medicine has secured a one-year delay in the deadline for moving to the ICD-10 diagnostic coding system, physicians and hospitals turn their attention to the work of transitioning from ICD-9. The American Medical Association and other physician organizations said the delay did not go far enough to alleviate concerns about the substantial costs and other burdens associated with the upgrade.

On Aug. 24, the Centers for Medicare & Medicaid Services issued a final rule that effectively changed the date for complying with the new ICD-10 medical data code sets to Oct. 1, 2014.

The agency decided to pursue the one-year delay in lieu of other alternatives, such as keeping the original 2013 deadline, or bypassing ICD-10 altogether and waiting to adopt ICD-11. “We believe a delay in the ICD-10 compliance date will increase the readiness of the industry at large, and thus avoid a large disruption in health care claim payments,” the final rule stated.

But even with the extra time, learning all of the new codes that ICD-10 will require a physician practice to submit on claims will be extremely cumbersome, said Michael Speer, MD, president of the Texas Medical Assn. “For example, there are 480 codes for a fractured kneecap alone — up from a grand total of two in the current system.”

Physicians will be dealing with adopting the new coding sets on top of numerous other Medicare incentive programs, said Steven J. Stack, MD, chair of the AMA Board of Trustees. ICD-10 alone “requires physicians and their office staff to contend with 68,000 codes — a fivefold increase from the current 13,000 codes,” he said.

The AMA had requested at least a two-year delay in the ICD-10 adoption deadline, asking CMS in a May 10 letter to conduct a cost-benefit analysis first to see what the financial and administrative implications would be of transitioning to ICD-10. Practices working to familiarize themselves with a much larger coding system may have to provide additional training to physicians and office staff as well as upgrade their health information technology to comply.

But doctors will have to be ready for this transition, because private health plans and government payers, already ahead of the game on implementation, “are going to force the issue,” said Greg DeBor, a managing director at Manatt Health Solutions, a national policy and strategic business advisory group. Payers have a simpler route to transition to ICD-10. All they have to do is accept the codes “and enforce their business rules against them. They don’t have to worry about how the claim is coded the way the physicians and hospitals do. They’ll have it ready to go by the deadline and will be saying to doctors, ‘If you want to get paid, you better give me your claims’ ” using ICD-10, he said.

Fred Ralston Jr., MD, an internist in Fayetteville, Tenn., and past president of the American College of Physicians, said his practice should “be able to attach an ICD-10 code of some sort to most of our diagnoses by the deadline. We are making sure that physicians are aware that every code needs to be addressed, and this will take significant physician time and involvement.” He said his practice could have done a much more careful job of transitioning to the new system had CMS granted the AMA’s request for a two-year delay.

Per-physician, the uncompensated costs of compliance with ICD-10 could be in the thousands of dollars “and countless additional hours of work for existing physicians and staff,” Dr. Ralston said. The AMA has estimated that total compliance costs could run as high as $2.7 million for large practices.

Hospitals that treat a wide variety of patients in their emergency departments as well as inpatient and outpatient settings probably face the biggest implementation burdens, although many facilities already have started work on this, DeBor said. By comparison, solo and primary care physicians “have a lot of similarly coded types of visits,” so the burden shouldn’t be as great in terms of training staff and changing conding systems, he said.

DeBor said larger group specialty practices that are involved in a wide variety of diagnoses but haven’t yet started their prep work on ICD-10 are likely to benefit the most from the one-year delay.

The American Health Information Management Assn. says the coding upgrade is long overdue. Physicians and hospitals currently use the ICD-9 system for billing medical services, which uses far fewer codes that don’t allow for as much specificity in listing patient diagnoses. AHIMA maintains that the new ICD-10 system would be more conducive to national payment and quality reforms.

Still, some doctors questioned the merits of a more diverse coding system. It provides the opportunity to collect more details on patients, but “I’m not sure how ICD-10 provides any better care” to patients, said Gary McWilliams, MD, executive vice president and chief ambulatory services officer at University Health System in San Antonio.

Dr. Stack said the AMA would work with federal regulators in the coming months to reduce the burdens associated with ICD-10 compliance, freeing up more time for doctors to interact with their patients. “This is not the final action on this issue,” he said.

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ADDITIONAL INFORMATION

More specificity means more codes

By Oct. 1, 2014, physician practices will need to be using the more complex ICD-10 coding system to list patient diagnoses on claims for public and private payers. Supporters of the mandate say it will enhance quality improvement by providing more information about individual patients’ care, but critics say the burdens associated with learning tens of thousands of new codes will divert resources away from patient care. Here are two examples of the additional level of detail allowed by ICD-10 that results in a much greater number of total codes.

ICD-9 code

851.42 — Cerebellar or brain stem contusion without mention of open intracranial wound, with brief [less than one hour] loss of consciousness

Comparable ICD-10 codes

S06.371A — Contusion, laceration, and hemorrhage of cerebellum with loss of consciousness of 30 minutes or less, initial encounter

S06.372A — Contusion, laceration, and hemorrhage of cerebellum with loss of consciousness of 31 minutes to 59 minutes, initial encounter

S06.381A — Contusion, laceration, and hemorrhage of brainstem with loss of consciousness of 30 minutes or less, initial encounter

S06.382A — Contusion, laceration, and hemorrhage of brainstem with loss of consciousness of 31 minutes to 59 minutes, initial encounter

ICD-9 code

01.59 — Other excision or destruction of lesion or tissue of brain

Comparable ICD-10 codes

00500ZZ — Destruction of brain, open approach

00503ZZ — Destruction of brain, percutaneous approach

00504ZZ — Destruction of brain, percutaneous endoscopic approach

00B00ZZ — Excision of brain, open approach

00B03ZZ — Excision of brain, percutaneous approach

00B04ZZ — Excision of brain, percutaneous endoscopic approach

Source: “General Equivalence Mappings, Documentation for Technical Users,” Centers for Medicare & Medicaid Services (link)

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