Compliance: Streamline Your ICD-10 Implementation Efforts

Part of your 2012 plan must include concentrating on your most common codes.

In spite of recent rumors, CMS has no intention of delaying the implementation of ICD-10 beyond the Oct. 1, 2013 date. That means every physician group should be taking steps toward the transition of ICD-9 coding to ICD-10 medical coding.

Know Penalties for Nonparticipation

Question: What are the penalties for entities that are covered under HIPAA who decide not to use ICD-10 codes as of Oct. 1, 2013?

Answer: Your claims will be denied -- and you technically could face fines since using the ICD-10 codes falls under the HIPAA transaction code set regulations.

From a practical viewpoint, as of service dates of Oct. 1, 2013, in case you still use ICD-9 codes and don't use ICD-10 codes, most probably your claims will be returned and will be asked to transition to ICD-10.

The penalties are the similar penalties that any HIPAA entity would be subject to. Most of you are acquainted with the ongoing HIPAA transaction code set penalty that calls for a maximum of $25,000 per covered entity per year, however the HITECH legislation of last year in fact upped those transaction and code set penalties, and they can be as much as $1.5 million per entity per year. So evidently it behooves everybody -- Medicare and Medicaid inclusive -- to ensure you are compliant with these ICD-10 codes by the Oct. 1, 2013 date.

LCD Updates Could Come Later

Question: The Medicare local coverage decisions (LCDs) presently list the payable ICD-9 codes that match up to all Medicare-payable procedures. Will contractors issue updated LCDs to the public before the Oct. 1, 2013 implementation date to demonstrate the payable ICD-10 codes for the procedures?

Answer: The answer to that isn't that clear yet. The LCDs will be translated as they will need to be translated, [but] as it relates to having them accessible to the public before the implementation date, that is not certain yet, as CMS is working fast and furious on all of its ICD-10 implementation efforts.

Shape Down Your Code List

Question: What can your practice do to get ready for the ICD-10 conversion?

Answer: One thing you won't need to do is keep in mind a bunch of new codes. In fact, most practitioners perhaps don't know many ICD9 codes by heart, so they won't be expected to memorize ICD-10 codes either.

Strategy: You must use your list of the top diagnoses that your practice gets to find the corresponding ICD-10 codes , and you've got your cheat sheet. Then, make certain that your coders are trained, that your claims are form 5010 compliant, and that your claim submission system supplier is ICD-10-ready. Besides, in case you have an electronic medical record or you plan to get one, make sure it can handle ICD-10. In case you're starting to bring in an EMR, you want to convert to ICD-10 first, not bring one in under ICD9 coding and then convert.