Countdown to ICD-10 Winds Down as October 1 Start Date Approaches

Although AAO-HNS stayed up to date on legislative activities, “the Academy’s recent efforts have been focused on CMS, the regulatory implementation, and preparing members for the ICD-10 transition,” Dr. Denneny said. However, he added, AAO-HNS “did sign on to AMA [American Medical Association] letters urging CMS to publish further data on ICD-10 testing results, EHR [electronic health record] vendor readiness, details on avoiding adverse impacts on quality measurement, risk mitigation plans, and more. We were pleased to see the July announcement from CMS and the AMA about efforts to limit ICD-10-related burdens on physicians.”

The CMS/AMA joint announcement came out on July 6 announcing an implementation period for ICD-10 that is intended to create some flexibility while everyone gets used to the new code set. The CMS guidance states that “for 12 months after ICD-10 implementation, Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family of codes.” (“Family of codes” refers to the ICD-10 three-character category headings.)

“This means that Medicare will not deny payment for these unintentional errors as practices become accustomed to ICD-10 coding,” wrote AMA President Steven J. Stack, MD, in an AMA Viewpoints post. “In addition, Medicare claims will not be audited based on the specificity of the diagnosis codes as long as they are from the appropriate family of codes. This transition period will give physicians and their practice teams time to get up to speed on the more complicated code set.”

Technical Difficulties

Time will be needed, given expectations for a relatively steep learning curve as physicians and staff adapt to the dramatically expanded code set. With the significant differences between ICD-9 and ICD-10, plans for testing the system in advance were a key topic of conversation in the medical community and on Capitol Hill. March 3-7, 2014, marked the initial testing week. During this acknowledgment testing, testers submitted more than 127,000 claims and were able to receive acknowledgments that the claims were accepted. The initial testing period was considered insufficient by many, because it did not represent true end-to-end testing.

In response to urging from the medical community, CMS announced three end-to-end testing periods in 2015, to involve a total of 2,550 volunteers. The testing periods included the submission of test claims to Medicare and then a subsequent response, called a remittance advice (RA), explaining the adjudication of the claims. With the testing periods, CMS intended to demonstrate that providers could successfully submit claims through Medicare, that software changes made at CMS to support ICD-10 result in appropriately adjudicated claims (based on the pricing data used for testing purposes), and that accurate RA documents are produced.