In light of last week's abrupt turn of events and everyone in Congress debating over the sustainable growth rate bill (HR 4302), particularly based on its potential to delay ICD-10 implementation, one question stands out in my mind: Can ICD-10 just be optional this year? Those who are ready could go ahead and use ICD-10; those who are not, for whatever reason, could have another year. If enough people get on board with ICD-10 and prove that it works, then it can become mandatory a year from now.
One can only imagine that many have delayed their training waiting to see if it would really happen. Even after CMS Administrator Marilyn Tavenner, assured us on Feb. 27, 2014 that ICD-10 would go forward as planned with no more delays1, here we are again wondering what to believe. If ICD-10 is delayed again, nobody will ever have any reason to believe that it will be implemented in the U.S. What would stop Congress from delaying implementation again next year or at any time up until the day before another scheduled go-live? Why devote more time and energy to something that continues to be an unbelievable reality? If given the chance to avoid the 2014 deadline, those who are not prepared will continue to find something more important to do with their time (like treating more patients) and their money, until they have no choice.
Those who have already spent millions of dollars in preparation, readiness assessment, training, documentation reviews and non-productive employee hours, should be allowed to move forward and begin using ICD-10 in October 2014. Most of the Medicare carriers across the U.S. and Medicaid agencies in various states have already begun ICD-10 testing with successful outcomes. Some commercial payers, like Anthem BCBS, are also ready to test. For payers who are ready and providers who have done their homework, why not let them get started? Making it optional for now would ease the financial burden anticipated with the potential for claim delays by allowing for dual coding options gradually over the next year. Vendors who are not ready could continue working over the next 12 to 18 months instead of racing to be compliant by October 2014 and risk having done an inadequate job.
Hospitals ready to implement ICD-10 stand to improve their bottom lines if they have adequately trained their physicians to do a better job of documenting the patient's diagnoses. Currently, there is no way to track how much direct revenue is being lost on patients who are sicker than the documentation describes. Physicians have not been motivated to document more because they are not paid based on diagnosis codes for their professional services. As long as the documentation supports a medically necessary diagnosis code, one code is enough to get the physician's bill paid. This works with ICD-9-CM, even if it is an unspecified code. If the hospital bills for an unspecified diagnosis, it typically results in a lower diagnosis-related group and relative weight, which ultimately means lower reimbursement. Therefore, it is an advantage for the hospital to have coders and a clinical documentation improvement team working with every physician who enters their hospital to help them understand the need for greater specificity, even with ICD-9-CM coding. The time and money spent in documentation improvement efforts will prove beneficial to hospitals whether coding in ICD-9 or ICD-10.
I will admit that I have no idea what dual coding options would mean for payers trying to process claims. On the provider side, dual coding is already a reality. Claims for dates of service prior to ICD-10 implementation will still need to be processed in ICD-9; workers' compensation and liability insurance carriers are not required to follow ICD-10 regulations unless enforced by state laws. So coding in ICD-9 and ICD-10 will be necessary for at least a year following implementation. The best solution for everyone involved would be to have a one-year grace period; allow ICD-10 coding for those who are ready starting in October of 2014 and extend the compliance deadline until October 2015 for those who need more time.
1 Verdon, D. R. (2014, February 27). No delays for ICD-10, says Tavenner at HIMSS 2014. Retrieved March 28, 2014, from Medical Economics
http://medicaleconomics.modernmedicine.com/medical-economics/news/no-delays-icd-10-says-tavenner-himss-2014?page=full
Carol Hoppe has been in healthcare for more than 25 years. She has hands-on physician practice experience working in transcription, billing, collections, office management and various other roles. Ms. Hoppe received her certification through the American Academy of Professional Coders as a Certified Professional Coder in 2002 and through the American Health Information Management Association as a Certified Coding Specialist-Physician Based (CCS-P) in 2003. She received her Certified Professional Coding Instructor (CPC-I) certification through the AAPC and became an AHIMA-approved ICD-10 trainer in 2011. She holds a Bachelor’s degree in Business Management from Indiana Wesleyan University where she graduated with honors, summa cum laude.