If you have been paying attention at all, you are aware that the International Classification of Diseases, 10th Revision (ICD-10) will be implemented later this year. So why – if you’re like most of the physicians I’ve talked with recently – have you done little or nothing about it? Since the launch is more than 6 months away, why am I telling you (and I am) that this is a very bad idea?
Because there is much to do before the deadline arrives. On Sept. 30, you will be using ICD-9 codes, and the next day you will have to begin using ICD-10. There is no transition period; all ICD-9–coded claims will be rejected from Oct. 1 forward, and no ICD-10 codes can be used before that date. Failure to prepare will be an unmitigated disaster for your practice’s cash flow.
The Centers for Medicare & Medicaid Services has already rejected a request from medical organizations for another 1-year delay (in addition to the one granted last year), so further extensions are highly unlikely. So you’ll need to be ready if you expect to be paid come October.
First, you will need to decide which parts of your coding and billing systems, and electronic health record (EHR, if you have one) need to be upgraded, how you will do it, and what it will cost. Then, you must get familiar with the new system.
Coders and billers will need the most training on the new methodology, but physicians and other providers also must learn how the new codes are different from the old ones. In general, the biggest differences are in level of documentation and specificity, but there are many brand-new codes as well.
I suggest that you start by identifying your 20 or 30 most-used diagnosis codes and then study in detail the differences between the ICD-9 and ICD-10 versions of them. Once you have mastered those, you can go on to other, less-used codes. Take as much time as you need to do this; remember, everything changes abruptly on Oct. 1, and you will have to get it right the first time.
Be sure to cross-train your coders and other staff members. If a crucial employee quits in the middle of September, you don’t want to have to start from square one. Also, ask your employees to plan their vacations well in advance – and not during the last 3 months of the year. This will not be a good time for the office to run short staffed.
Next, I suggest that you contact all of your third-party payers, billing services, and clearinghouses. Start with the payers responsible for the majority of your claims. Be aggressive; ask them how, exactly, they are preparing for the changeover, and stay in continuous contact with them. Unfortunately, many of these organizations are as behind as most medical practices in their preparations.
Many payers and clearinghouses (including CMS) will be staging "test runs," during which you will be able to submit "practice claims" using the new system. Payers will determine whether your ICD-10 code is in the right place and in the right format, whether the code you’ve used is appropriate, and whether the claim would have been accepted, rejected, or held pending additional information. You will have to do this for each payer, because each will have different coding policies; those policies have not yet been released, and in some cases, have not even been developed.
The CMS will run its first testing opportunity in March; you can register for it, or for future tests, through your local Medicare Administrative Contractor (MAC) website.
You can use these testing opportunities to test your internal system as well, ensuring that everything works smoothly from the time you code a claim until payment is received. Select commonly used ICD-9 claims and practice coding them in ICD-10. The American Academy of Dermatology offers a nice ICD-9/ICD-10 "crosswalk," along with other training aids, at its website.
Even the best laid plans can go awry, so it would be prudent to put aside a cash reserve, or secure a line of credit, to cover expenses during the first few months of the transition, in case the payment machinery falters and large numbers of claims go unpaid. For the same reason, consider postponing major capital investments from mid-year until early 2015.
You may have heard that ICD-10 is only a transition system; that ICD-11 will be following closely on its heels, only a year or 2 later. Many of the experts that I’ve spoken with feel that this highly unlikely, and I agree. So don’t feel that you are wasting your time adjusting to ICD-10; in all probability, we will be using it a lot longer than CMS is expecting.