A recent announcement from the Centers for Medicare & Medicaid Services (CMS) and the American Medical Association (AMA) was certainly a welcome surprise to most of us. There were actually three items involved: the announcement, the additional guidance document, and a letter to Medicare providers.
Everyone I’ve talked to has felt that this was a good step.
First of all, it indicates that AMA may be ceasing its resistance to ICD-10 and helping physicians prepare for the transition. That’s a very important climate change.
I was on a webinar last week in which some attendees weren’t even aware that there were both CM and PCS codes under ICD-10. Others questioned if CPT codes would still be used. This shows that there’s still a lot of education that’s needed. Having AMA help with this education will mark a big step forward.
The announcement confirms the date as Oct. 1 and removes doubt about additional delays or a potential dual-use period. There is even a statement in the announcement indicating that “Medicare claims processing systems won’t have the capability to accept ICD-9 codes for dates of services after Sept. 30.” Our members feel that this should help encourage everyone to move forward and not be worried about additional delays or a “soft launch.” However, many are still worried about a last-minute change to allow this.
There’s still some confusion regarding the announcement. It’s important to note that it does not change the actual requirements in the HIPAA regulation, which never have included a dual-use period for ICD-10. However, some have mistaken the announcement to mean that there is a dual-use period, and that it would apply to everyone. Some of this misunderstanding may have been fueled by people just reading headlines in newsletters reporting about easing up on requirements. If you don’t read the full article, you miss the details. This misperception needs to be addressed quickly by the industry.
This is a Medicare-specific announcement and does not suggest that Medicaid or private payers follow the same path by accepting less-specific codes. Some of our members have expressed concern that a provider might select a less-specific code that is not actually a billable code (just using the three-digit category for some conditions, for example). If the code is not billable, it could be rejected. This raises the question of what CMS meant by a “family” of codes. CMS has indicated that it will issue guidance on this shortly. Some members also are concerned that providers would select a less-specific code for private payers, and that this could increase risk of fraud or impact information used in utilization management or other functions.
As far as private payers changing their approach as a result of this announcement, it’s generally felt that it’s too late in the game for payers to make any significant changes to their policies and applications. Many are shutting down testing at this point to make final preparations for the transition.
About the Author
Jim Daley is the immediate past chair of WEDI and serves as the chair of the WEDI ICD-10 Workgroup.
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