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.

Health Management Technology published an article that suggests seven ways to spend your extra ICD-10 preparation time wisely. Included in these tips are suggestions to:

  • Determine how much time coding will require and if hiring additional staff is necessary
  • Ensure all parties involved will receive proper education prior to implementation date
  • Check with business partners and healthcare technology vendors on their plan to handle the transition
  • Review payor contracts and update terms for the ICD-10 code set
  • Establish an adequate line of credit now to cushion ICD-10’s impact on your cash flow

White Plume Technologies would recommend that practices consider which and how many ICD-10 codes will be added to your current superbill. If you are still using a paper form, determine if you will be able to fit the number of ICD-10 codes on to a single sheet of paper or if you need to consider an electronic superbill option. If transitioning to an electronic form, start this process at least 7-8 months prior to the ICD-10 start date to pace the change in physician workflow.  

White Plume has a plan for current customers and can accommodate the exact number of codes your practice needs into your future ICD-10 super bill. Current clients can learn more at the ICD-10 training and other training classes found here. For others interested in White Plume and our solutions for the future with ICD-10, contact us.   

Healthcare Technology Selection Guide and Guidance

Physician practices are concerned with finding EMR software that meets the needs and requirements of their particular organization. CTS Guides, a research company located in Rockville, MD offers a free Medical Software Selection Kit to help healthcare practices compare and review software options, define needs, prepare questions to ask vendors during demos, and gain more control over the software selection process. The kit provides software reviews, comparative product ratings including over 800 features, and a template to plan and rate vendor demos. To find out more about CTS and access the kit, click here.

Of course, no EMR or PM system is perfect. Ideally, each practice would employ an EMR and PM system vendor that would create a version to completely fit their situation. Without a perfect option, you should choose the best option for your circumstances. The following articles will help prepare you for the technology selection process ahead:

  • Want a plethora of Medical Group Management Association’s (MGMA) EMR/EHR recourses? Visit a list here.
  • How should you selecting the right EMR vendor for your circumstances? HIMSS’ article explains.
  • What should you consider before changing PM systems? Read about this here.
  • Want to know one vital component most EMR vendors offer but most practices fail to use, leading to denied claims? Read this article. 

Modifier Rule Education

As anyone in the coding world knows, modifiers are a critical component for accurate billing and maximum reimbursement. The notorious complexity of modifier rules creates considerable lag when it comes to the forms review and editing process. The questions below highlight key factors that must be taken into account when applying modifiers to procedures.  What…

KX Modifier Overpayment

On April 20, the Office of Inspector General (OIG) published a report explaining the use of the KX modifier. Seen most often with physical and occupational therapy billing, providers add a KX modifier to CPT® or HCPCS codes in order to show there is documentation on file justifying the need for that procedure, service, or supply, and the documentation meets Medicare coverage criteria.

Of the claim samples reviewed, the OIG found less than 50 percent of the claims containing a KX modifier had the appropriate supporting documentation. As such, the OIG estimates contractors paid approximately $316.4 million in unallowable Medicare payments to suppliers.

According to the report,

“These errors occurred because the contractors did not supplement their electronic edits with sufficient prepayment and post payment review to ensure that suppliers maintained required documentation. The edits could determine only whether the required KX modifier was on the claims and did not prevent payments for unallowable claims.”

Providers may soon begin receiving letters from insurance companies that pay for durable medical equipment (DME) in an attempt to recoup overpayments.

Since the problem with the KX modifier is from lack of documentation, adding an edit in your practice’s code review engine (e.g., AccelaSMART) can remind the coder to verify there is proper documentation before submitting the claim. When asked to pay back the contractor, first attempt to refile the claim with proof of documentation for the service. If no documentation is available, then repayment must be made.

Correctly Code Rapid Flu Tests

When it comes to lab tests, one common area of missed revenue occurs with Rapid Flu tests. Doctors can purchase test kits for the Rapid Flu Test (87804) which tests for both A & B strains. Swabs are taken from the patient’s respiratory tract and the claim is coded based on the test results. If…

Work Smarter Not Harder—In Medical Coding

In the AAPC article “Diagnosis Code Overload,” Jeremy Reimer discusses the problem of over-coding that sometimes appears when reviewing medical records. His example is a case where a patient had sustained injuries in a relatively minor motor vehicle accident.  The provider filed a claim with fourteen (14) diagnosis codes.

Reimer brings to light several unspecified and ill-defined codes from category 780-799 that were inappropriately used to describe symptoms for a known medical condition. Physicians often end up using ill-defined or unspecified codes (e.g., 780-799) when other more accurate diagnosis code options are available.

Paper encounter forms and EMR templates usually list only the most commonly used or generic diagnosis codes (e.g., 780-799) to conserve space and provide quick coding selections for the physicians. However, as Reimer’s example shows, what may be convenient for the physicians may also be inaccurate in terms of medical coding. This is when a coding review tool is helpful.

Coding review engines can review claims to check for existing LCD and NCD policies, create filters for common under-coding scenarios, and provide look up tools for coders who need to find a more accurate diagnosis code for a documented condition.  

Reimer suggests that physicians will sometimes need to be reminded of basic coding principles. The current HCFA 1500 claim form still only allows 4 diagnosis codes per line item. Even with the 5010 crossover, there is still a limit of 12 diagnosis codes that may be reported per claim. Reimer’s example does not specify what procedures or exams were documented with this claim, so we do not get a complete picture of the medical record. Regardless, any claim with 14 diagnosis codes is instantly suspicious.

The repeated demands by insurance companies to “document, document, document” may lead physicians to mistakenly believe that selecting more diagnosis codes satisfies documentation requirements—but it does not. When it comes to capturing the events of a patient encounter, medical coders must work with their physicians to help them work smarter, not harder.

Revised ICD-10 Implementation Date Proposed: October 1, 2014

Today the Secretary for the Department of Health and Human Services (HHS), Kathleen Sebelius, announced a proposed rule to delay the original ICD-10 compliance date from October 1, 2013 to October 1, 2014. You can download the entirety of the 200 paged “proposed rule” that intends to save the healthcare industry 4.6 billion dollars here.

The initial decision to delay the original ICD-10 implementation date occurred as a result of increasing pressure by the medical community and the American Medical Association. Thankfully, the HHS listened to the public and realized the medical industry needed more time to prepare for ICD-10.

Not enough delay to justify procrastination  

The ICD-10 implementation delay is helpful, but is no reason to slow down in planning for the eventual cutover of your practice to ICD-10.  The switch to ICD-10 will impact both the clinical and business sides of your practice. Successfully navigating the transition is a system-wide change which will require significant planning, resources and lead time. 

Providers should not count on HHS to delay ICD-10 implementation again.  While HHS granted providers more time with this proposal, it may not be as much as you think if your practice was already behind in ICD-10 planning.

Join the discussion

Let us know what impact the proposed 12 month delay will have on your practice.  Join the discussion below.

White Plume Technologies continues on its ICD-10 development pathway to complete all components well in advance of the original ICD-10 target date. 

The Ongoing Search for the Perfect Practice Management System

I speak with clinics representing as many as 30 specialties, ranging from small practices of a few providers to practices consisting of hundreds of providers, nearly all of which have one thing in common: They are adopting new practice management systems.

No Such Thing as Perfect PM System

One thing is certain, no two clinics are alike. Not in workflow, billing needs, or in what they see as priorities for their organizations. In an ideal world, each system would be implemented in a fully customized fashion to meet the needs of a practice. Unfortunately, we don’t live in such a world. There is no “out of the box” perfect practice management system for a clinic. There is, however, a best solution for each individual clinic. 

Ask: Why are you Changing?

Too often I speak with clinics that are in the process of changing PM systems that are unable to answer the question, “Why exactly are you changing systems?” The few who answer often reply with a vague: “the physicians wanted to,” “we feel like there is a better solution out there,” or “the clinic next door just signed paperwork with a new system.” 

If you are thinking of changing, consider the following steps to start the decision process:

  • List specifically what you are looking for in a new system.
  • Read it out loud. If it makes sense, evaluate. There is certainly an advantage to knowing your options.
  • Take a questionnaire that walks you through the new vendor/PM selection process
  • Ask your current vendor for a list of features and functionality they have customized for your clinic over the years. Make sure any alternative systems can accommodate established clinic workflow and procedures.   
  • Consider: Are you maximizing your current system? You may find that some or all of your desired functionality already exists in the system you have already paid for!

Years are spent perfecting current workflows, processes, and procedures around existing technology in order to create the perfect practice management system. If an EHR is driving your purchase, is it worth the disruption to implement a new practice management system as well? Or, would you consider taking the “best of breed” approach?  

Choosing a New PM System

If you decide to choose a new PM System:

  • Be sure the new vendor can accommodate your clinic’s requirements.  
  • Ask for several references of the new system.
  • Ask clear and specific questions about the new system and vendor.

Unfortunately, clinics often experience tremendous disappointment after implementing a new system—usually a result of not completing enough new vendor research. While it is easy to believe purchasing a new system will solve all current frustrations, clinics often find that they are simply replacing their known problems with a new set of frustrations.   

I challenge clinics to do their homework. Take a step back and look at the bigger picture. Take a moment before valuable time and resources are invested in a new system and answer the question, “Why are you looking to replace your current system?” Are you using your current system for everything it has to offer?

— Shelley Scarbrough, Client Account Representative, White Plume Technologies

With ICD-10 Delay, ICD-11 Enters the Conversation

CMS administrator Marilyn Tavenner hinted at a delay in ICD-10 implementation when speaking to an AMA meeting on Tuesday, February 14, 2012. Rather vaguely, Tavenner said CMS would “reexamine the timing” of ICD-10 implementation. Two days later Health and Human Services (HHS) Secretary Kathleen Sebelius removed all doubt when she stated that HHS “announces intent to delay ICD-10 compliance date.” 

Undetermined Delay to ICD-10

Unfortunately, no one in the industry knows how long this delay may last. 

Tom Sullivan, editor of Government Health IT, published an intriguing blog post four days later introducing the idea that there may be a case for leapfrogging ICD-10 and going directly to ICD-11—depending on the length of the ICD-10 delay. Sullivan points out that ICD-9 was essentially completed in the early 1970’s and thus reflected 1960’s theories of health and technologies; likewise ICD-10 was completed in 1990, therefore reflecting 1980’s thinking. 

After the 2012 ICD-10 summit, a poll was taken with over 50 senior healthcare professional participants. Among the findings were:

“Nearly two-thirds of respondents (64 percent) believe a delay will not improve readiness, 76 percent believe a delay will harm other healthcare reform efforts, and 69 percent say a two-year delay would be either ‘potentially catastrophic’ or ‘unrecoverable.’”

Skipping ICD-10 and Adopting ICD-11

If the delay to the ICD-10 changeover is going to take an additional year, should everyone just wait for one big jump to ICD-11? The main benefit would be to allow physicians and healthcare practices to have one big transition rather than two in short succession. One of the biggest arguments against skipping ICD-10 is that ICD-11 is simply not ready yet for “prime time”.

“ICD-10 is the pathway to ICD-11. You have to treat it like you’re building a structure starting with a first floor. You can’t build a fourth one without constructing a second and third.”
–Sue Bowman, Director of Coding Policy and Compliance for the American Health Information Management Association as quoted by ICD10Watch.

According to HIPAA’s Final Rule, published in the Federal Register, “the earliest projected date to begin the rule making for implementation of a U.S. clinical modification of ICD-11 would be the year 2020.”  The CDC will require several years to make the clinical modification required for adoption of ICD-11 in the United States.

Of course, the actual decision will depend on the length of delay of the ICD-10 implementation and the speed of completion of ICD-11.

Delay Implementation, Not Planning

Regardless of what happens providers must act now to prepare for a substantial adjustment in the number of codes included on paper superbills and in electronic charge capture systems. After all, there was a reason for the delay: Many practices were not ready to meet the ICD-10 deadline. Now you have more time before you have to turn your school project in—wouldn’t you rather be done with it (i.e., planning) early and feel relieved while the rest of the industry is sweating?

White Plume Technologies continues on its development pathway to complete all components well in advance of the original ICD-10 target date. 

White Plume Hosts 5.0 Rule-Building Lab

White Plume offered its first ever “5.0 Rule-Building Lab” in February.  In this two hour WebEx session, clients on AccelaSMART 5.0 and higher gathered to ask questions,  learn more and share successes of using the powerful and flexible rule builder found in AccelaSMART. 

100% of the participants reported they would suggest the lab to a colleague.

Many thanks to the clients who participated and for the excellent examples and feedback they provided which helped make the session a success.  The response was extremely favorable and White Plume is looking forward to offering similar sessions in the future. If you are interested in being notified of upcoming sessions, you can email support@whiteplume.com.

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