On Monday, the Centers for Medicare and Medicaid Services (CMS), along with the American Medical Association (AMA), announced efforts to help providers ease into the transition to ICD-10 scheduled to take effect October 1, 2015.
Perhaps most significant among the provisions, while the October 1, 2015, deadline stands and beginning with October 1, 2015, dates of services, all diagnoses added to claims must be listed with ICD-10 codes, CMS will not deny any claims for a lack of specificity in the coding.
According to a prepared Frequently Asked Questions document, “while diagnosis coding to the correct level of specificity is the goal for all claims, 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.”
A similar exception will be made for codes submitted as part of a CMS quality program. No penalties will be assessed based on the 2015 reporting year if the provider failed to meet reporting guidelines based on specificity of coding, as long as the the provider chose a code from the correct family of codes. As well, CMS will not deny informal reviews of quality program outcomes based solely on ICD-10 specificity, and providers will not be penalized if CMS has difficulty calculating quality scores as a result of the transition to ICD-10.
Two other provisions of Monday’s announcement include the creation of a communication and collaboration center to monitor ICD-10 implementation overseen by an ICD-10 Ombudsman who will work closely with representatives in CMS’s regional offices to address physicians’ concerns, and the establishment of an advance payment, which may be available to providers in the event that Part B Medicare Administrative Contractors (MACs) are unable to process claims in a timely manner as a result of problems with ICD-10. In the event such a problem occurs, the individual MACs will post guidelines for applying for an advanced payment. CMS will not provide advanced payments for problems resulting solely from a provider’s inability to submit claims as a result of ICD-10.
Though a long-time critic of ICD-10, the AMA joined forces with CMS to implement this transition period in order to help ease the burden on physicians. “These provisions are a culmination of vigorous efforts to convince the agency of the need for a transition period to avoid financial disruptions during this time of tremendous change,” wrote AMA President Steven J. Stack, MD in a recent AMA Viewpoints article. “These provisions are a testament to the power of organized medicine and what we can achieve when we band together for the good of our patients and our profession.”
For more information about the transition period, review the announcement or the Frequently Asked Questions sheet from CMS and the AMA. For more information about preparing for ICD-10, review these resources:
- The CIPROMS article, Preparing for ICD-10: A Primer for Emergency Physicians.
- The CIPROMS article, Preparing for ICD-10: A Primer for Anesthesiologists.
- The CMS “Road to 10” website aimed specifically at smaller physician practices, which includes webcasts, references by specialty, timelines, and more.
- An AMA Wire® special series on what you need to do to prepare for the transition.
- The AMA’s ICD-10 Web page with information and resources on implementation planning, cross-walking between ICD-9 and ICD-10, and readiness testing.
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