ICD-10 Preparation: Not Planning to Transition to ICD-10 as of Oct. 1, 2013? You Might Be Liable to Face Millions in Fines, CMS Reps Say

Plus: CMS officials are considering how to handle dates of service that span the pre- and post-ICD-10 implementation dates.

If you think the ICD-10 codes won't apply to your Medicare claims as of Oct. 1, 2013, CMS has news for you--not only will your claims be denied if you continue to submit ICD-9 codes to Medicare after that date, but you could face fines. CMS representatives shed light on this and several other issues during the agency's May 18 "ICD-10 National Provider Teleconference," and we've broken down the five FAQs that best apply to Part B practices.

Question 1: How will CMS handle claims that span from before Oct. 1, 2013 through dates after Oct. 1, 2013? Should the practitioner use ICD-9 or ICD-10 codes for these claims?

Answer: CMS is mulling how to handle this situation, but hasn't yet arrived at a firm decision. "We are getting very close to finalizing our decision for all claim types, including professional claims, supplier claims, and the various types of institutional claims," said CMS's Sarah Shirey-Losso during the call. "Some claims will continue to use the discharge date, some will use the ‘from' date, and some may be required to be split," she said.

Stay tuned: CMS is currently working on a final decision, which the agency will issue in a "Change Request" document this summer.

Date of service issue: If, however, you submit a claim for a single date of service, you'll submit ICD-9 codes for dates of service through Sept. 30, 2013, and ICD-10 codes for dates of service Oct. 1, 2013 and thereafter. For instance: If you send in a claim on Oct. 15, 2013, but the date of service is Sept. 1, 2013, you'll still use ICD-9 codes.

Question 2: Will workers' compensation insurers still use ICD-9, even after the rest of the industry transitions to ICD-10 after Oct. 1, 2013?

Answer: The answer to that is unclear, but CMS has heard murmurs that workers' comp. insurers will switch over to ICD-10.

"We've heard anecdotally that even though they're not required to transition to ICD-10, that many of them are planning to, just because it's more practical to do so and they see that it's the way the rest of the industry is going," said CMS's Denise Buenning, MsM, during the call.

What about Medicaid? You can rest assured that Medicaid insurers will be transitioning to ICD-10 as of the Oct. 1, 2013 date, Buenning said. CMS is working with Medicaid administrators to ensure that they are compliant by the implementation date, she noted.

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