CMS has since publicized the results of two of the three testing periods. Testing held Jan. 26-30 resulted in an 81% acceptance rate among 661 participants, and testing held April 27-May 1 resulted in an 88% acceptance rate among 875 participants. A third testing period was held July 20-24, 2015.
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September 2015Members of the AAO-HNS “were involved in the end-to-end testing for otolaryngology, and over time we saw improved results,” Dr. Denneny said. “We had members participate in both the January end-to-end testing week and in April. Participants were able to successfully submit ICD-10 test claims and have them processed through Medicare billing systems.”
Another aspect of the technical challenge is that Oct. 1, 2015, happens to be a Thursday, which means that claims submitted on Wednesday that week will need to be handled differently than those submitted on Thursday. One of the biggest challenges is that “we are having literally the entire medical system turn on a dime on Oct. 1,” Dr. Waguespack said. Additional challenges, he said, include documenting to the appropriate level of specificity and learning to report comorbidities—such as how an injury occurred or whether a patient is a smoker—as part of the new code sets.
Further, there will be a period of time in which claims need to be processed in both formats, depending on dates of service. Billing professionals will have to be extra vigilant and watch service dates for a while to ensure that claims are processed correctly.
Despite the newly introduced flexibility with ICD-10, the switch off of ICD-9 will be a hard stop. Although some have called for a dual use period, CMS stated in both a July 7 letter to providers and a July 24 list of “clarifying questions and answers” that ICD-9 will not be accepted as of Oct. 1. CMS also has been clear that although Medicare is allowing an implementation period, third-party payers are not held to the same requirement. The guidance will be adopted by the Medicare administrative contractors, the recovery audit contractors, the zone program integrity contractors, and the supplemental medical review contractor.
Similarly, the guidance does not change the coding specificity required by the local coverage determinations (LCDs) or national coverage determinations (NCDs), and claims may be denied because the ICD-10 code is not consistent with an applicable LCD or NCD policy.
Learning the New Code
One especially important way to be prepared for the go live is to provide staff training ahead of time. Staff training will be key for ensuring a smooth transition to the new coding set and for keeping the day-to-day practice of documenting and billing on track. To help ensure that staff members are successful after ICD-10 goes live and that there are minimal disruptions to practice, categorize the staff members who need to receive training and at what levels, coordinate the timeline for training and working with the team on completion, identify the training format that works best for the team (e.g., classroom, online, conference), decide on the amount of downtime for the office during training, and identify the additional resources staff members will need after training is completed.