Washington Update on ICD-10 - March 2015

February was a busy month in Washington DC for parties interested in ICD-10.  The big question on everyone’s mind is will it get delayed again?  ICD-10 has already been delayed three times, twice by CMS and most recently last March by Congress.

The repeated delays make it difficult for anyone to say with certainty what will happen in the future.  The government is a bit like the boy who cried wolf, but remember at the end of that story the people who suffer are the owners of the sheep!

CMS Administrator Marilyn Tavenner reports successful completion of first end-to-end ICD-10 testing.  Testing was completed with over 600 providers and 14,000 claims.  81% of claims were accepted with 6% of claims rejected for ICD-9 or ICD-10 related errors.  CMS will offer to other periods of end-to-end testing April 27-May 1 and July 20-July 24.

Energy and Commerce Subcommittee on Health held a Congressional Hearing on ICD-10 on February 11th to listen to updates on stakeholder preparation.  Six of the seven panelists were in favor of moving forward with ICD-10 on October 1, 2015 with the lone dissenter concerned about implementation costs for small physician practices.

The Government Accountability Office (GAO) released a report on February 6th detailing CMS response to Stakeholder concerns.  It was these concerns that ultimately delayed ICD-10 in 2014.  Senate Finance Committee Chairman Orin Hatch (Republican, Utah) and Ranking Member Ron Wyden (Democrat, Oregon) said the report “gives them confidence” that CMS is adequately preparing for the switch to ICD-10 in 2015.

All three of these events point towards holding the line on the current ICD-10 conversion date of October 1, 2015.  We share many of Dr. Terry’s concerns for physician practices to successfully transition to ICD-10. 

My recommendation would be to prepare for ICD-10 to happen in 2015.  Join me for a webinar focused on how to prepare for ICD-10 and protect physician productivity.

The Danger of Unspecified ICD-10 Codes

Everyone is familiar with the external cause codes in ICD-10.  We have hear examples of walking into a lamppost, bitten by a turtle, or a water skier injured due to water skis on fire.  These examples provide some levity, but many of these examples exist in ICD-9 and will rarely be used in ICD-10.

Today, I want to look at an area of ICD-10 coding (and ICD-9 coding) that is more dangerous and very common in physician practices; unspecified codes.


Unspecified codes exist in ICD-9, but many people do not realize these unspecified codes also exist in ICD-10.  Unspecified codes are used by many practices to save space on their paper superbill, where there is not room to list out all of the available (and more specific) code choices.  As a result, some of the most commonly used codes in ICD-9 are unspecified codes.

If you have converted your most frequently used ICD-9 codes to ICD-10 codes, your conversion analysis may be underestimating the difficulty of transitioning to ICD-10 because of these unspecified codes.  Most applied mapping tools take an ICD-9 code and show all of the potential options in ICD-10, but these tools typically do not show ICD-10 choices that would be more appropriately associated with a more specific ICD-9 code.

For example, a practice may have 715.96 – OA Knee on their superbill.  The long description of this code is actually Osteoarthrosis, unspecified whether generalized or localized, lower leg.  A mapping tool may show this as a simple 1 to 1 conversion, with the resulting ICD-10 code being M17.9 – Osteoarthrosis of knee, unspecified.

The potential problem in this example is that ICD-10 has 10 additional osteoarthosis of the knee codes that are more specific.  Most in the industry agree that the entire point of migrating to ICD-10 is to provide more detail to provide better health outcomes and ultimately reduce healthcare expenses.  The question is how will payers respond when a claim is submitted with this unspecified code, rather than a more specific ICD-10 code that identifies whether the osteoarthrosis was primary or secondary?  Or which knee: right, left or both?

Payers have never adjudicated ICD-10 claims and will be learning as they go.  We do not know how payers will handle these unspecified codes, but practices need to be prepared to respond as they get feedback from the payers.  An additional complication is that all payers will not handle these codes the same way at the same time.

To protect cash flow, practices should examine which unspecified codes are frequently used in their practice today and be prepared to use more specific ICD-10 codes if and when they are required by their payers.

A Practical Guide to ICD-10...you will never use many of those crazy codes!

I am sick and tired of hearing about the huge increase in the number of codes in ICD-10.  How many times have we heard about 69,000 codes in ICD-10?  While we are on the subject of things that get under my skin, if I hear about a Subsequent Encounter for Burns due to water skis on fire, I might set myself on fire!

These arguments are red herrings used as scare tactics to obfuscate the real issues.

Yes, there are 69,000 diagnosis codes in ICD-10CM.  Yes, V91.07XD is the ICD-10 code that describes the aforementioned water ski burn.  However, ICD-9 has 16,000 diagnosis codes today, many of which are just as ridiculous.  These codes are rarely used in ICD-9 and will rarely be used in ICD-10. 

spaceman spiff

(ICD-10) V95.40XA – Unspecified Spacecraft accident injuring occupant, Initial Encounter

(ICD-9) E845.0 – Accident involving spacecraft injuring occupant of spacecraft

water skis

(ICD-10) V91.07XD – Burn dues to water-skis on fire, subsequent encounter

(ICD-9) E837.4 – Explosion, fire or burning in watercraft injuring skier


(ICD-10) T14.8 – Other injury of unspecified body region

(ICD-9) 959.9 – Unspecified site injury

Many of these comical examples are external cause codes.  These codes are rarely used in ICD-9 and CMS has clarified that they are not required for ICD-10.  If your practice is not using these codes today, you will not have to use them in ICD-10.

Rather than focusing on the thousands of unused (but entertaining) ICD-10 codes, most practices should be worried about how many codes their practice will actually need to use in ICD-10.  The best way to do this is begin with the ICD-9 codes your practices uses today.

Here are some steps to get started:

  1. Run a frequency report out of your billing system.  For most practices somewhere between 200-300 ICD-9 codes cover 95% of their encounters.
  2. Convert these codes into ICD-10 using a mapping tool.
  3. Compare the results to see which ICD-9 codes are easily converted to ICD-10 and which are more complicated.

Bonus Tip: Be careful of unspecified ICD-9 codes translating to an unspecified ICD-10 code, these can cause unintended negative consequence for your revenue cycle.

FREE ICD-10 Conversion Analysis

 White Plume provides FREE ICD-10 conversion analysis.

Many practices struggle with how to begin working on their ICD-10 project.  They know the risks to physician productivity and cash flow caused by ICD-10, but it is difficult to communicate the impact to staff and physicians.

One of the BEST ways to get started is to show them the impact to YOUR practice based on the diagnosis codes you use most frequently today. 

All you have to do is email an Excel file with your most commonly used ICD-9 codes.  We will send you back summary data that reports back high level analysis data in addition to the line by line detail.


Sample Conversion Analysis:



ICD-10 Costs for Physician Practices

In 2008, Nachimson Advisors published a landmark paper projecting the cost of implementing ICD-10 in physician practices.  On February 12, 2014 an updated study was published with additional details and revised projections.  The study projects total ICD-10 costs to range from $21,000 - $82,000 per provider.

ICD-10 is Coming, White Plume can Help

Given the letters CMS sent to AHIMA and AMA last month, it seems clear there is no intention to delay the ICD-10 conversion again.  With less than 7 months before October 1, 2014, the time to prepare is now.  Preparation involves more than just system upgrades.  Practices need to consider how physicians will be impacted, specifically in the areas of charge capture and documentation.  Then take the next step to determine how changes in those two areas will impact the revenue cycle.

ICD-10 Threatens Physician Productivity

Carl Natale of ICD-10 Watch wrote an article recently discussing the trends to watch in 2013 when it comes to preparing for ICD-10. He makes the point that one of physician’s greatest complaints about ICD-10 is surrounding the time and money it will take to make the conversion to ICD-10.  A physician’s time is money, so as with most things, it comes down to the cost as compared to the benefit (be that literal or perceived). Most physicians would argue, from their perspective, the benefit does not outweigh the cost.

ICD-10 Delay: What To Do With Your Time

The Department of Health and Human Services’ (HHS) announcement of a proposed rule that would delay ICD-10’s implementation compliance date by a year—to October 1, 2014—has allowed the industry to sigh with relief. However, there are reasons for the delay. If indeed the industry was unprepared for the 2013 transition, perhaps as a result of the unfortunate yet educational 5010 transition difficulties, action should be taken now.

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