When I last wrote about the International Classification of Diseases, 10th Revision (ICD-10) – last year, at about this time – the switchover was scheduled to take place on Oct. 1. Shortly thereafter, of course, Congress decided to delay the inevitable for 1 year. While the House Energy and Commerce Committee has hinted at the possibility of further postponements, we must all assume, until we hear otherwise, that the day of reckoning will arrive as scheduled. You will need to be ready if you expect to be paid come October.
Remember, on Sept. 30 you will be using ICD-9 codes, and the next day you will have to begin using ICD-10. There is no transition period; all ICD-9–coded claims will be rejected from Oct. 1 forward, and no ICD-10 codes can be used before that date. Failure to prepare will be an unmitigated disaster for your practice’s cash flow.
First, decide which parts of your coding and billing systems – and EHR, if you have one – need to be upgraded, how you will do it, and what it will cost. Then, you must get familiar with the new system.
Coders and billers will need the most training on the new methodology, but physicians and other providers must also learn how the new codes are different from the old ones. In general, most differences are in specificity and level of documentation (left/right, acute/chronic, etc.), but there are new codes as well.
I suggest you start by identifying your most-used 20 or 30 diagnosis codes, and then study in detail the differences between the ICD-9 and ICD-10 versions of them. Once you have mastered those, you can go on to other, less-used codes. Take as much time as you need to do this: Remember, everything changes abruptly on Oct. 1, and you will have to get it right the first time.
Be sure to cross-train your coders and other staff members. If a crucial employee quits in the middle of September, you don’t want to have to start from square one. Also, ask your employees to plan their vacations well in advance – and not during the last 3 months of the year. That goes for you, too. This will not be a good time for you to be away, or for the office to run short-staffed.
Next, I suggest you contact all of your third-party payers, billing services, and clearinghouses. Be aggressive; ask them how, exactly, they are preparing for the changeover, and stay in continuous contact with them. Unfortunately, many of these organizations are as behind as most medical practices in their preparations.
Many payers and clearinghouses (including the Centers for Medicare & Medicaid Services) are staging test runs during which you can submit practice claims using the new system. Payers will determine whether your ICD-10 code is in the right place and in the right format; whether the code you used is appropriate; and whether the claim would have been accepted, rejected, or held pending additional information. You will need to do this for each payer, because each will have different coding policies. Many of those policies have not yet been released, and, in some cases, have not even been developed.
You can register for CMS testing sessions through your local Medicare Administrative Contractor (MAC) website. Use the sessions to test your internal system as well, to ensure that everything works smoothly from the time you code a claim until payment is received. Select commonly used ICD-9 claims and practice coding them in ICD-10. The American Academy of Dermatology offers an assortment of training aids at its website, aad.org.
Even the best-laid plans can go awry, however, so it would be prudent to put aside a cash reserve or secure a line of credit to cover expenses during the first few months of the transition, in case the payment machinery falters and large numbers of claims go unpaid. For the same reason, consider postponing major capital investments until early 2016.
You may have heard that ICD-10 is only a transition system; that ICD-11 will be following closely on its heels. I doubt it. In all probability, we will be using ICD-10 a lot longer than CMS originally planned. Besides, ICD-11 is essentially a refinement of ICD-10, not the significant departure that the 10th revision is over the 9th.
Dr. Eastern practices dermatology and dermatologic surgery in Belleville, N.J. He is the author of numerous articles and textbook chapters, and is a longtime monthly columnist for Dermatology News.