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 SNF Providers, Advocates Brace Themselves For ICD-10 Readiness

ICD-10 is coming. But providers and CMS may not be completely prepared for its implementation, some advocates and government watch groups say.
Oct. 1 is the day the Centers for Medicare & Medicaid Services (CMS) officially transfers from the International Classification of Diseases, Ninth Revision (ICD-9) to the International Classification of Diseases, Tenth Revision (ICD-10). These code sets are used to report to the agency medical diagnoses and inpatient procedures. Every provider must use this latest code, not just those who submit Medicare and Medicaid claims.
Procedure codes are expanding from 14,000 to 70,000 for physicians and from 4,000 to 72,000 for hospitals. Under the new system, there are codes for ailments such as “underdosing of caffeine.” Another example: Cardiologists who provide angioplasty for their patients now have not just one but 845 codes for the procedure.
The ICD-10 transition affects every part of practitioners’ practices, from software upgrades, to patient registration and referrals, to clinical documentation and billing. Providers must comply with the new code and use it for services on or after the Oct. 1 date.
To date, CMS has provided extensive ICD-10 educational resources. (The agency has postponed its conversation three times since its original announcement in 2011.) Yet, questions remained regarding skilled nursing facility (SNF) services. The American Health Care Association (AHCA), an advocate representing more than 10,000 SNFs, sent a formal letter to CMS in August. Specifically, it asked about:
* Whether the ombudsman would also be able to field questions related to SNFs, just as with those to physicians and other providers;
* Whether Medicare Part B reviewers would also give SNFs the 12-month diagnosis flexibility that is given to physicians and other providers to learn the system;
* Whether services rendered by SNFs also fall under CMS/American Medical Association guidance;
* Whether CMS will have the Minimum Data Set (MDS) ICD-10 edits in place (If not, then claims could be counted as late and not receive prompt payment.);
* Whether the MDS assessments need to be submitted in September or October; 
* Whether an updated version of the “Medicare Code Editor: Definitions of Medicare Code Edits,” which was last published in October 2014, will be out soon; and
* Whether CMS can provide contractor training in joint replacement V codes with ICD-9 (now Z codes with ICD-10) and acute fracture codes. (In recent years, SNFs have had bills delayed or denied because of problems with principal diagnosis coding.)
Last night, AHCA received a response from CMS. Two key answers were provided. One, that the ICD-10 ombudsman will be able to assist SNFs. And two, that MDS assessments with Assessment Reference Dates (ARDs) on or before Sept. 30, 2015, must contain a valid ICD-9 code. SNF claims with ARDs on or after Oct. 1, 2015, need to have a valid ICD-10 code.
In a note to its members, AHCA recommends that “SNF clinicians, MDS assessment coordinators, and billers review the Q&A document before submitting claims and MDS assessments that include October 2015 dates of service.”
Yet much angst remains among providers. An August survey by Navicure/Porter Research shows that an “overwhelming majority (94 percent) of participants” anticipate an immediate increase in their denial rate, with 56 percent of respondents citing ICD-10’s impact on revenue and cash flow as their top concern.
A recent Government Accounting Office report also does not assuage the agita. Despite CMS using $116 million to update and prepare its system for the transition, the agency cannot predict its readiness until implementation on Oct. 1.
“While CMS’ actions to update, test, and validate its systems and plan for contingencies can help mitigate risks and minimize impacts of system errors, the extent to which any such errors will affect the agency’s ability to properly process claims cannot be determined until CMS’ systems begin processing ICD-10 codes,” the report says.
Jackie Oberst is Provider’s managing editor. Email her at Follow the magazine on Twitter @ProviderMag and @ProviderMyers.
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