Posts Tagged ICD-10

Taking CDI Into the Physician Office Setting

Taking CDI Into the Physician Office Setting

 

CDI, or Clinical Documentation Improvement, is as familiar to physicians who practice in the hospital as other acronyms such as ICU, OR, ED – but in the physician office, CDI is relatively unknown. However, with the implementation of the Merit-Based Incentive Payment System, or MIPS, CDI in the physician office will become imperative.

Most physicians will fall under the MIPS provisions of MACRA, the Medicare Access and CHIP Reauthorization Act. CMS estimates that of the 1.3 million providers under MACRA, 1.2 million will be under the MIPS program. The Quality component of MIPS is familiar to most physicians, as it is similar to the previous Physician Quality Reporting System. One new aspect of MIPS, however, is the Resource Use or Cost. This component will be 10 percent of the physician’s MIPS score in 2018, increasing to 30 percent in 2019 and beyond. The Cost score will be derived from claims data and will be based on the CPT and ICD-10-CM codes billed. Correct and specific ICD-10-CM coding will be key to physician reimbursement in this model. Medicare, and other payers implementing similar reimbursement strategies expect that a patient with a certain diagnosis will incur an estimated cost. If the cost to treat the patient far exceeds the estimate, then the physician’s Resource Use/Cost score will be low – he/she will be considered to be an inefficient physician.

A specific example to illustrate this:  The physician treats a patient with diabetes. The only code he bills for this patient is E11.9 – Type 2 diabetes mellitus without complications.  However, this patient has diabetic retinopathy, diabetic neuropathy, and diabetic chronic kidney disease. The payer’s estimated annual cost for a patient with diabetes with no complications is $1,400, but this patient incurs much higher costs due to his complications.  The physician, therefore, appears to be inefficient, and his Resource Use/Cost score will suffer. The payer’s estimated cost for a patient with diabetic chronic kidney disease is $4,300. Had the physician coded as specifically as he could have, E11.319 for diabetic retinopathy, E11.40 for diabetic neuropathy, and E11.22 for diabetic chronic kidney disease, the higher cost would have been expected, and the physician would not be penalized for the care he is rendering.

One hindrance to CDI in the physician office setting is the use of electronic medical records and the implementation of “charge passing”, codes transmitting directly from the EMR into the practice billing system. Physicians may not choose the most specific, or even the most accurate, diagnosis code, but once those codes are passed onto the claim and filed to Medicare, there is no changing or correcting that information. Corrected claims will not be accepted for this purpose. Some practices use coders to review these claims before they are actually filed.  This usually does not involve 100 percent review of the documentation, but it would allow some coding errors to be caught. For example, if a coder noted the following diagnoses on the claim:  E11.9, N18.5, G62.9, he would be prompted to discuss with the physician that N18.5 – chronic kidney disease, stage 5, and G62.9 – neuropathy, are considered to be diabetic complications and should be coded as such. And if a coder is familiar with coding guidelines, understanding that certain diagnoses require additional codes, then when she notes G30.9 – Alzheimer’s disease on the claim, she can query the physician as to which additional code is appropriate, F02.80 – dementia in underlying disease without behavioral disturbance or F02.81 – dementia in underlying disease with behavioral disturbance.

This may require additional diagnosis coding training for physician office coders, and it will almost certainly require a change in mindset. Physician coders have focused on what is documented with the mantra “Not documented, not done.” But CDI requires a similar focus on seeing what is not documented, what should be there, what is likely true for that patient – and then querying the physician.

Electronic medical records have also contributed to some of the errors seen in that physician may not have been trained properly in diagnosis documentation and coding before having access to what is essentially the entire ICD-10-CM book in their EMR. The ICD-10-CM descriptions may not match the language the physician uses, although the code is correct. For example, in ICD-9-CM, the code for depression, unspecified was 311, and the description was Depressive disorder, not elsewhere classified. In ICD-10-CM, the code for depression, unspecified is F32.9, and the description is Major depressive disorder, single episode, unspecified. Physicians may not be able to identify the appropriate code without further diagnosis education. EMR vendors and office staff may try to set up shortcuts to assist the physicians in choosing the appropriate diagnosis code and create further issues. Two recent errors I have seen in my own auditing practice:  1.) physicians coding Crohn’s disease with small bowel obstruction when they intended to code for small bowel obstruction, unspecified and 2.) physicians coding psychophysiologic insomnia when they intended to code chronic insomnia. CDI in the physician office setting must include a detailed review of the ICD-10-CM code descriptions in the EMR.

CDI in the physician office setting does not have to be as formal a process as that seen in the hospital – it can be informal discussions with the physicians. It can be accomplished through real-time shadowing or end-of-day review, but it must occur before the claim is filed. A simple CDI process could look something like this:

  • Coder reviews record for correct coding based on physician documentation.
  • Coder talks with nurse and physician about code choices.
  • Coder identifies incorrect codes chosen – discovers confusing language in ICD-10 description.
  • Coder reviews with physician and makes changes in code descriptions to assist physician in most specific and correct coding.

The keys for coders will be continuing education, which may be in the form of informal chats with the physicians and clinical staff, review of ICD-10-CM guidelines and Coding Clinic guidance, review of medical policies which can be used to help guide physicians in documenting. And perhaps most importantly, respect for the physician’s priorities. The physician’s foremost interest is care of the patient, and CDI is simply helping the physician to understand that how he documents matters and providing the assistance he needs to make it so.

References

Medicare Quality Payment Program

Kim the Coder (also known as Kim Huey, MJ, CCS-P, PCS, CHC, CPC, CPCO, COC) works with clients to improve coding and documentation of services and to ensure compliance with Medicare and insurance company regulations. Ms. Huey is available for on-site visits for auditing and education as well as for on-the-record audits and general coding and reimbursement questions.

 

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Letter to the Editor: Ever Been Bitten by a Killer Whale?

Dear Editor,

Ever been bitten by a killer whale? Have you sustained burns while waterskiing? Been hit by a spaceship? Know someone who was sucked into a jet engine more than once? Though these sound bizarre, if a new and controversial medical coding system goes into place a year from now, those are exactly the kind of questions doctors across Alabama will soon have to ask patients in order to list a patient’s diagnosis and treatment plan.

When a patient is examined by a doctor, the patient’s diagnosis and treatment plan are “coded” by the doctor. Each diagnosis and prescribed treatment, everything from broken bones and sprained ankles to more serious incidents such as cardiac events and strokes, has a code number. These codes are established by the World Health Organization to classify diseases and other health-related problems.

The present list of codes being used, ICD-9 (International Classification of Diseases, 9th Edition), contains roughly 13,000 codes. While updates are periodically required to keep up with changes in medicine, the switch from ICD-9 to ICD-10 is massive, with nearly 70,000 new and oftentimes bizarre codes that will add little or nothing to the care of patients. Indeed, in most cases, it will require considerably more time than the current system to find the right code, taking away from the time a doctor can spend with his or her patient. Everyone involved in the delivery of health care who submits claims to insurance companies – from doctors to hospitals – will be affected.

In theory, these new codes could allow for better tracking of health threats, like infectious diseases. But, there’s no indication that switching coding systems will really improve the care of patients. Health care should be about the patient, not the paperwork.

The Medical Association of the State of Alabama believes there has not been enough testing of this new system, particularly in rural areas, like so much of Alabama. Do Americans really need a code for “hurt at the opera?”

Bizarre codes aside, this issue is quite serious and the stakes are high. Patients trust their physicians to diagnose and treat them to the best of their ability so the patient’s health can improve. But if physicians can’t find a code or put down the wrong code, insurance companies may delay or even deny necessary treatments.

While better testing by the federal government would ease some of the concerns my colleagues and I have regarding ICD-10, there’s little or no indication that this totally new coding system will improve delivery of health care. I can’t help but wonder whether the switch to ICD-10 might mirror the launch of Healthcare.gov, which technicians are still trying to debug. Patients can’t wait that long for their treatments.

While our medical coding system may need updating, now is not the time as the entire American health care system is still reeling from implementation of the Affordable Care Act. With the 2017 due date of ICD-11 right around the corner, we’ll be doing this all over again in less than three years.

“Head banging into wall, multiple encounters…” wonder if there’s a code for that?

Ronald Franks, M.D.
President,
Medical Association of the State of Alabama

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ICD-10: Headache for Doctors; Heartache for Patients

*Below is the letter Medical Association and President Ronald Franks sent to Alabama’s Congressional Delegation urging support to delaying implementation of ICD-10 until October 2017..

Jan. 7, 2015

Dear Alabama Congressional Delegation;

On behalf of the Medical Association of the State of Alabama and our more than 7,000 physician members, we urge you to support delaying implementation of the new medical coding system known as ICD-10 until October 2017.

Forced adoption of this new coding system, which is scheduled for Oct. 1, 2015, will require everyone in a medical practice who touches a patient’s chart – from the physician to the person submitting the claim to the insurance company – to learn four times as many new medical codes as the current system, ICD-9. While the 16,000 medical codes in ICD-9 are well-known, ICD-10 contains more than 68,000 diagnostic codes. There are more than 250 codes for diabetes alone, and with four times as many codes as ICD-9, the government and insurance companies will have four times as many reasons to use ICD-10 coding mistakes to deny medical care!

While spending more time with patients is what patients and physicians want, under ICD-10 we will instead spend more hours in front of a computer screen scanning 68,000 medical codes looking for the right one. Not only will ICD-10 have no direct medical benefit for patients, this mandate is also a tremendous financial burden for medical practices already operating on shoestring budgets. The U.S. is the only country implementing all 68,000 new codes and the only country tying a massive coding system to a complex billing system. Further, experts from the Centers for Medicare & Medicaid Services warn physicians may not get paid for three to six months due to ICD-10’s extensive and complicated implementation. With the likely improbably the system works properly by Oct. 1, 2015, medical practices can’t absorb such long delays in payment.

The transition to ICD-10 is expected to cost more than $1.64 billion over 15 years, with more than 40 percent of that expense coming from the cost of upgrading information technology systems for different participants including the government, insurance companies, physicians and hospitals. While many hospitals are in favor of ICD-10 implementation this year, the people treating patients and responsible for navigating all 68,000 codes – physicians – stand firmly against implementation and in favor of a two-year delay. Physicians will be hardest hit by ICD-10 since the massive cost of software and training is not as easy to spread over a small medical group as it is over an entire insurance company, hospital system or government agency.

Forced adoption of ICD-10 has very real consequences for physicians and the timing could not be worse, when financial strain on medical practices is at its highest point in history. As physicians struggle to implement costly electronic health records and meet stringent quality measures under Medicare’s Physician Quality Reporting System, at the same time we never know when Congress might allow the flawed Medicare SGR formula, or “doc fix,” to expire, further cutting already inadequate Medicare payments by 20 to 30 percent. While our patients want better care and society demands innovation, physicians are drowning under a tsunami of government regulations, and adopting ICD-10 this year will only add to the problem.

Please don’t force this on medical practices this year. Instead, help us by stopping mandates like ICD-10 that stretch our resources and limit the time we spend with our patients. With ICD-11 coming in the near future, we ask your support for a delay of ICD-10 at least another two years so we can change how it will be implemented to protect physicians and patients. We may find that skipping ICD-10 entirely and moving to ICD-11, which is more compatible with electronic medical records, makes more sense. Please tell Speaker Boehner, Chairman Fred Upton and Chairman Pete Sessions that delaying ICD-10 for two years is a priority.

Thank you for your consideration.

Dr. Ronald Franks
President, Medical Association of the State of Alabama

Cc: U.S. Sen. Jeff Sessions
U.S. Sen. Richard Shelby
U.S. Rep. Robert Aderholt
U.S. Rep. Mo Brooks
U.S. Rep. Bradley Byrne
U.S. Rep. Gary Palmer
U.S. Rep. Martha Roby
U.S. Rep. Mike Rogers
U.S. Rep. Terri Sewell

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Alabama Physician Lone ICD-10 Dissenter During Congressional Hearing

MONTGOMERY – As the lone voice for physicians in a room filled with insurance company and hospital representatives, Jeff Terry, M.D., a Mobile urologist, urged a Congressional panel not to implement a massive revision to medical coding known as ICD-10, which he believes could force doctors out of business and threaten patients’ access to medical care.

“The vast majority of America’s physicians in private practice are not prepared,” Dr. Terry told the U.S. House Energy and Commerce Health Subcommittee last week. “Physicians are overwhelmed with the tsunami of regulations that have significantly increased the work for our practices. Physicians are retiring early, which could leave countless numbers of patients without a doctor.”

Dr. Terry’s and most physicians’ viewpoint on ICD-10 is at odds with insurance companies and hospital systems, which can more easily absorb the cost of new technology, training and personnel that ICD-10 compliance will require. Small medical practices can’t shoulder the burden of this “costly unfunded mandate” so easily Dr. Terry, a past president of the Medical Association of the State of Alabama, said.

While the current medical coding system ICD-9 has 13,000 codes, ICD-10 contains more than 68,000 codes including more than 250 for diabetes alone. Though other countries have adopted ICD-10 already, the United States is the only one planning to implement all of the 68,000 new codes and link both a massive coding and complex billing system together.

Unless Congress takes action, ICD-10 will be implemented on Oct. 1, 2015, adding to the growing list of government regulations Dr. Terry said makes it more and more difficult to provide the quality care his patients want and deserve.

“It is harder and harder to keep the patient as the primary focus in our daily activities. ICD-10 is viewed as another expensive distraction with little demonstrated value to improving patient care. The huge costs certainly outweigh the very few benefits. Based on data from other countries, doctors will be forced to reduce the numbers of patients they see after ICD-10 is implemented,” Dr. Terry said.

View the press release

Watch Dr. Terry’s testimony.

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Flawed Implementation of ICD-10 Less than Six Months Away

*Editor’s Note: The following is a special editorial from Dr. Jeff Terry, past president of the Medical Association, who has closely followed ICD-10 and testified before Congress concerning the need to delay implementation to mitigate the negative effects on medical practices.

Please don’t discount the cry for help coming from more than 90 percent of the physicians in this country. Please don’t overlook the obvious as far as what ICD-10 will really do to patient care, physicians’ practices and the medical profession. Please understand that 90 percent of the ICD-10 proponents will gain tremendously financially from ICD-10 implementation. Finally, please understand that ICD-10, along with all the other government mandates on medicine simply further removes the patient from the center of the health care equation and it gives physicians less time to listen to, talk to, and examine the patient. We are placing the computer in the middle of the patient-physician relationship where it doesn’t belong.

Physicians are scared. They are barely keeping up with the new electronic medical record system. Many physicians have to learn four or five different EMRs because they practice at different hospitals. We can’t use our own words anymore to describe our patient’s condition, our diagnosis and our plan. All of our comments, physical findings, orders and plans for care must fit into computer templates and other artificial ways to document. Part of the problem is trying to teach a generation of older physicians how to use the computer; another part of the problem is many different computer vendors that still haven’t figured out the right way to do it; and the final part of the problem is a meaningful use system which is anything but meaningful that forces us to do unnecessary work. Once a physician invests in an EMR he becomes a slave to that particular system because it is too expensive for most to make a change.

Physicians understand that coding is for statistics and has nothing to do with our patient care and is certainly not accurate enough to do medical research with, yet these are arguments that CMS and others use to convince Congress of the need for ICD-10. Also please understand the biggest untruth, which is that we are behind the rest of the world because no one else in the entire world has even come close to implementing an ICD-10 system like our government has proposed! Physicians are sending a very strong message that the present implementation of ICD-10 is extremely flawed and doesn’t make any sense. Physicians are sending a loud message that Congress/CMS must change the implementation of ICD-10 or many physicians will find themselves leaving the medical profession (willingly and unwillingly) and thousands of patients will be left without a doctor.

The best solution to this ICD-10 problem is to do what H.R. 1701 and S 972 from last year ask for: Delay ICD-10 and at the same time have a non-biased committee study the problem and come up with answers in the next six months. The study is needed because there are also many unintended consequences of this change that will also adversely affect the medical profession and patient care that CMS has not addressed yet. I understand the political reality, and CMS may not want to do this because the pro ICD-10 coalition is working so hard to the one-day implementation on 10/1/15. If this is not possible, then CMS must figure out a way to have a two-year transition period where physicians gradually transition into ICD-10 without having their payments go to zero for several months. Perhaps allowing a dual system for three to four months to start off and then accepting “generic” ICD-10 codes and not requiring the more specific codes for a couple of years.

Please see this non-biased article in Modern Healthcare from April 10, 2015. It points out the fact that many are not yet ready, and I testified to the Health Care Subcommittee of Energy and Commerce that no matter how much time you give us we will never be ready for a one-day implementation. It is like asking someone to run a four-minute mile or to fly an airplane all by yourself without real-time practice. It is not logical to think that our profession can do this. There must be a transition period. The industry may say that they are ready and 80 percent will be able to do it. What about the other 20 percent? Let’s assume only 5 percent of doctors don’t get it right. That means we lose 5 percent of our profession because of a coding system that will not actually help in the day to day care of our patients. These doctors will go out of business and for each physician we lose there will be 2,000 patients looking for a new doctor. This will happen in the district of every member of our Congress. Is this what America wants? We can do better!

Now that SGR is fixed, ICD-10 will be organized medicine’s top priority. ICD-10 must be urgently addressed because uncertainty is not fair to anyone, and the present plan for implementation will mean disaster for patients, physicians and the medical profession overall.

W. Jeff Terry, M.D.
Past President, Medical Association of the State of Alabama
Chair, Alabama Delegation to the American Medical Association
Legislative Affairs Committee, American Urological Association
Member, The National Physicians Council for Health Care Policy

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Bill in U.S. House Would #StopICD10

Rep. Ted Poe (R-Tex.), supported by six of his Republican colleagues including Rep. Mike Rogers (R.-Ala.) and Rep. Mo Brooks (R.-Ala.), has introduced a bill to block the government-mandated transition from ICD-9 to ICD-10 diagnostic codes set to take effect Oct. 1.

Dubbed the Cutting Costly Codes Act of 2015, the legislation would prohibit the Secretary of Health and Human Services from requiring the medical community to comply with the ICD-10 codes and instead allow the U.S. Government Accountability Office to conduct a study by consulting with medical community stakeholders to determine steps to “mitigate the disruption on health care providers resulting from a replacement of ICD-9 as such a standard,” according to a new article from Medscape Medical News.

“The new ICD-10 codes will not make one patient healthier,” Rep. Poe said in a news release. “What it will do is put an unnecessary strain on the medical community who should be focused on treating patients, not implementing a whole new bureaucratic language.”

Critics of the legislation argue the legislation will go no further than its predecessor in April 2013, which failed to get out of committee. While the medical community made a concerted push to repeal the sustainable growth rate once and for all earlier this year, no such effort has been made to delay or suspend the implementation of ICD-10 in October.

Small physician practices, especially in rural areas, will be further stretched to afford the transition costs associated with ICD-10, where physicians that work for hospitals or large health care systems have the funding to stay afloat during the transition and have little to no desire to delay implementation, according to the article.

The Medical Association’s Past President W. Jeff Terry, M.D., has been extremely vocal on the consequences of implementation of ICD-10 on small physician practices – even being the lone physician to testify before Congress to voice concerns should ICD-10 be implemented later this year.

While the Medical Association supports Rep. Poe’s legislation and is working to build support in the Alabama Congressional Delegation for ICD-10 delay, physicians are encouraged to make plans to prepare for the mandated transition should ICD-10 delay efforts prove unsuccessful.

“ICD-10 is a government mandate that will actually put some physicians and some hospitals out of business if they are not able to comply with this mandate all on one day on Oct. 1,” Dr. Terry said. “How can the government put a physician who has dedicated his entire life to his profession out of business with a mandate that is almost impossible to comply with? It’s like telling the physician he will need to run a five-minute mile to stay in business. I don’t care if you give him one or two years to comply; there are some things that just can’t be done. It’s not fair to physicians or the patients who will lose their physicians. We need to have someone with reason sit back and figure out a better way to implement ICD-10 to protect our profession. The proponents of ICD-10 have not acknowledged this problem at all, and they don’t acknowledge the millions of dollars they will receive when ICD-10 is implemented. There is a very big conflict of interest in this argument and there is a tremendous amount of bad information being circulated to justify ICD-10 even by CMS itself. Congress must act on this issue and do the right thing.”

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ICD-10 Switch Will Cause Problems in the ER

Researchers found 27 percent of the 1,830 commonly used emergency room ICD-9 codes had convoluted mappings that could create problems with reporting or reimbursement. Further, they found that when they looked at more than 24,000 actual clinical encounters in the ER, 23 percent could be assigned incorrect codes if recommendations of the Center for Medicare and Medicaid Services were followed.

During the past two years researchers extensively reviewed how ICD-9 codes map to ICD-10 codes, not only for emergency medicine, but for other problematic areas, including pediatrics, patient safety reporting and long-term research. Some ICD-9 indicator codes translate well, but many more have convoluted mappings — and some simply don’t map at all.

In their latest study, the UIC researchers looked specifically at the codes used most often by emergency physicians, to see where problems may arise.

“Despite the wide availability of information and mapping tools, some of the challenges we face are not well understood,” Dr. Andrew Boyd, assistant professor of biomedical and health information sciences at UIC and principal investigator on the study, said.

Problems due to ICD-10 will be more widespread for independent physician groups that staff EDs and perform their own billing, according to the report. They will be overwhelmed by the amount of analysis and challenges in ICD-10, so say the study authors.

Worries remain over ICD-10, especially for small practices. According to a survey from NueMD, a billing and practice management software vendor, the level of concern about ICD-10, especially among small practices, is “a little too high for comfort.” Legislation currently pending in Congress, dubbed the Cutting Costly Codes Act of 2015, sponsored by Rep. Ted Poe (R-Tex.), and supported by six of his Republican colleagues including Rep. Mike Rogers (R.-Ala.) and Rep. Mo Brooks (R.-Ala.), is an intention to block the mandated transition ICD-10 set to take effect Oct. 1.

The bill would also prohibit HHS from requiring the medical community to comply with the ICD-10 codes and allow the U.S. Government Accountability Office to conduct a study by consulting with medical community stakeholders to determine steps to “mitigate the disruption on health care providers resulting from a replacement of ICD-9 as such a standard,” according to a new article from Medscape Medical News.

“The new ICD-10 codes will not make one patient healthier,” Rep. Poe said in a news release. “What it will do is put an unnecessary strain on the medical community who should be focused on treating patients, not implementing a whole new bureaucratic language.”

While the Medical Association supports Rep. Poe’s legislation and is working to build support in the Alabama Congressional Delegation for ICD-10 delay, physicians are encouraged to make plans to prepare for the mandated transition should ICD-10 delay efforts prove unsuccessful.

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State Lawmakers Urge Congress to Delay ICD-10

MONTGOMERY ─ An Alabama Senate Joint Resolution urging Congress to delay the mandated implementation of ICD-10 on Oct. 1 and lessen the burden on Alabama’s medical practices was enacted this week.

“The Centers for Medicare and Medicaid Services is forcing this unfunded mandate on the health care community, and it couldn’t come at a worse time,” SJR 79 sponsor Sen. Tim Melson, M.D. (R-Florence), said. “Physicians are already overburdened by federal reporting regulations, such as meaning use of electronic health records and the Physician Quality Reporting System that will straddle the ICD-10 start date of Oct. 1. Adding ICD-10 to the mix will only make matters worse for physicians who are only trying to treat their patients.”

If implemented on Oct. 1, the International Classification of Diseases and Related Problems, 10th Version (ICD-10), will replace the current ICD-9 system requiring physicians and their office staff to transition to a coding system with more than 68,000 diagnostic codes – four times more than ICD-9’s current 13,000 codes. Though other countries have adopted ICD-10, the U.S. is the only country planning to fully adopt ICD-10’s complete catalog of 68,000 diagnostic codes and tie it to a medical billing system.

Jeff Terry, M.D., a Mobile urologist and past president of the Medical Association, was the only physician to testify before a Congressional panel earlier this year that the implementation of ICD-10 could force doctors out of business and threaten patients’ access to medical care.

“The vast majority of America’s physicians in private practice are not prepared,” Dr. Terry told the U.S. House Energy and Commerce Health Subcommittee. “Physicians are overwhelmed with the tsunami of regulations that have significantly increased the work for our practices. Physicians are retiring early, which could leave countless numbers of patients without a doctor.”

Physicians widely agree the conversion to the new coding system will not improve patient care, but the overnight conversion to the new system could provide insurers with four times as many reasons to deny necessary medical services and procedures for patients because of coding errors.

“CMS is putting the computer between the doctor and the patient with ICD-10,” Sen. Larry Stutts, M.D., (R-Tuscumbia), co-sponsor of the resolution, said. “As we saw with the rollout of the federal health exchanges, there were a lot of technical problems. With CMS planning to implement ICD-10 on one single day, there are no guarantees we won’t see the same types of problems again. Thirteen thousand codes are already too many. Instead of adding more complicated coding we need to simplify the process.”

Transitioning to ICD-10 requires an abundance of costly and time-consuming education for physicians and staff, software, coder training, and equipment testing. This unfunded mandate will be most costly for private medical practices forced to pay $80,000 to $2.7 million to complete the transition.

Read more about Act 2015-279 and delaying implementation of ICD-10.

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Association Supports Rep. Palmer’s ICD-10 “Grace Period” Bill

The Medical Association of the State of Alabama has endorsed H.R. 2652 by Congressman Gary Palmer (R-AL-06), which will protect patients’ access to care and lessen the burden on physicians, particularly in rural and smaller practices.

The “Protecting Patients and Physicians Against Coding Act” would give physicians a two-year grace period in which they would not be penalized for errors with the new federally mandated ICD-10 system that’s used to document code medical procedures and services. ICD-10 contains more than four times the codes used with ICD-9. For physicians, more time spent poring over tens of thousands of medical codes during a patient’s visit equates to less quality time with that patient.

“We are very concerned about the ICD-10 mandate,” George “Buddy” Smith Jr., M.D., president of the Medical Association, said. “Not only does it not improve patient care, but it may provide insurers four times as many reasons to deny necessary medical services and procedures because of coding errors.”

John Meigs, M.D., a family physician from Centerville and a member of the Medical Association’s Board of Censors, said he anticipates serious problems if H.R. 2652 is not adopted.

“The new coding system does nothing for patients or doctors. It’s for insurance companies and bean counters,” said Dr. Meigs. “It will get in the way of the care patients in rural areas badly need. There hasn’t been much in terms of a trial run. To avoid serious disruptions, there’s going to need to be a grace period where physicians get a chance to get used to this new system.”

Congressman Palmer thanked the Medical Association for supporting his bill, the “Protecting Patients and Physicians Against Coding Act.”

“Physicians and other health care providers are in the business to provide care, not to master a complicated and burdensome federally mandated coding system,” Congressman Palmer said. “Protecting patient access to health care is very important. Rural areas and small towns are most at risk from the implementation of ICD-10, practitioners in those areas with smaller practices tend to have fewer resources and they rightly focus on patient care instead of government coding. Because of this, I offered an amendment to recent to legislation delay ICD-10’s implementation. Unfortunately, the amendment was not accepted.”

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ICD-10: 75 Days and Counting

UPDATE July 17, 2015: ICD-10: 75 Days and Counting

Medical Association asks all health plans in Alabama to provide a One-Year “grace period”

Only 75 days remain until ICD-10 is scheduled for implementation but a step in the right direction was taken last week by CMS in announcing a 12-month grace period for physician coding errors in Medicare claims. This move by CMS is a direct result of pressure put on the agency from state medical associations nationwide and from members of Congress like Rep. Gary Palmer, who introduced a bill in the U.S. House with a similar grace period.

“While the Medical Association has been an outspoken opponent of ICD-10 and remains so, the inclusion of a grace period makes this federal mandate less problematic for medicine,” Medical Association President Buddy Smith, M.D., said.

Not 48 hours after breaking the news to Alabama doctors about the ICD-10 grace period, Dr. Smith penned a letter to all Alabama health plans and payers asking them to also provide a 12-month “grace period” for coding errors.

“While there are still many details to be worked out, this week’s announcement is a good start, and we will ask private payers and Alabama Medicaid to follow those same transition-period guidelines,” Dr. Smith wrote.

The Medical Association has been one of ICD-10’s most outspoken opponents, taking to the public and media examples of just some of the ridiculously specific codes that make up ICD-10.

Despite the controversy surrounding ICD-10, there has been room to poke a little fun at the hyper-specific coding system that includes some weird and obscure codes for bizarre medical injuries. There’s even an illustrated book, Struck by an Orca: ICD-10 Illustrated.

Additionally, the Association has been on the front lines educating members of Congress about the real-world effects ICD-10 will have on medical practices in Alabama.

“The new coding system does nothing for patients or doctors. It’s for insurance companies and bean counters,” John Meigs, M.D., a family physician from Centerville and a member of the Medical Association’s Board of Censors, said. “It will get in the way of the care patients in rural areas badly need. There hasn’t been much in terms of a trial run. To avoid serious disruptions, there’s going to need to be a grace period where physicians get a chance to get used to this new system.”

But the Association also employed educational and advocacy efforts closer to home with state lawmakers as well, especially in the Association-supported Alabama Senate Joint Resolution by Senators Tim Melson, M.D. and Larry Stutts, M.D.

However, not all physicians see ICD-10 as a problem and claim no outrageous expenses or ill effects on their practices during the transition, according to one news service.

“We did not have special training,” Edward M. Burke, M.D., of the Beyer Medical Group in Missouri, told the House subcommittee in February and reported in HCPRO online. “We did not spend ANY money in preparation. We did not see less patients, and our practice did not suffer. As providers, it was not frustrating or scary. It just was.”

To be clear, the Medical Association still opposes implementation of ICD-10 on Oct. 1, as Dr. Smith said, the grace period is “a good start.” However, we still have much work left to do, including preparing for the implementation in 75 days that no one wants to do. As well, questions remain, particularly regarding the grace period’s coverage of services provided by hospital-based physicians. The Association is asking CMS for guidance in this area and will provide that information to our members as soon as it becomes available.

Additionally, here are some other resources that may help in preparations for ICD-10:

The Medical Association will present “Update on ICD-10 and Quality Measures” on Saturday, Aug. 22, at Embassy Suites in Birmingham-Hoover. Register online here.


 

UPDATE July 8, 2015: Not 48 hours after breaking the news to Alabama doctors about the grace period, Medical Association President Buddy Smith, M.D., penned a letter to all Alabama health plans and payers asking them to also provide a 12-month “grace period” for coding errors.

“While the Medical Association has been an outspoken opponent of ICD-10 and remains so, the inclusion of a grace period makes this federal mandate less problematic for medicine,” Dr. Smith wrote. “… the Medical Association is requesting that all health care payers and health plans in the state of Alabama adhere to and adopt the most recent guidelines from CMS regarding a grace period for physician ICD-10 coding errors …”

Between our work with the Alabama Congressional Delegation to build support for Rep. Gary Palmer’s legislation calling for an ICD-10 grace period to passage of the Alabama Senate Joint Resolution requesting a penalty-free transition for doctors to the request that all Alabama health plans and payers also provide a grace period, the Medical Association has worked tirelessly to mitigate the negative impact that ICD-10 may have on medical practices and patient care.


 

UPDATE July 6, 2015: Responding to mounting pressure from physicians’ groups and Congress, the Centers for Medicare & Medicaid Services announced it will allow additional flexibility for physicians as they transition to ICD-10 on Oct. 1, beginning with a one-year reprieve from coding error penalties.

“The Medical Association has been on the ICD-10 front lines for a very long time,” George “Buddy” Smith Jr., M.D., president of the Medical Association, said. “While there are still many details to be worked out, today’s announcement is a good start, and we will ask private payers and Alabama Medicaid to follow those same transition-period guidelines.”

Dr. Smith noted the Association has worked with the Alabama Congressional Delegation and state officials on ICD-10 to find any way possible to mitigate the effects of the unfunded mandate on medical practices. In fact, the recent American Medical Association resolution calling for a ‘grace period’ was championed by Alabama physician Dr. Jeff Terry.

Today’s announcement addresses the following areas:

  • Claim denials. For the first year, Medicare claims will not be denied solely based on the specificity of the diagnosis codes as long as they are from the appropriate family of ICD-10 codes. Medicare will not deny payment for these unintentional errors as practices become accustomed to ICD-10 coding. Medicare claims will not be audited based on the specificity of the diagnosis codes as long as they are from the appropriate family of codes. This transition period will give physicians and their practice team’s time to get up to speed on the more complicated code set. Medicare Administrative Contractors and Recovery Audit Contractors will be required to follow this policy.
  • Quality-reporting penalties. Similar to claim denials, CMS will not subject physicians to penalties for the Physician Quality Reporting System, the value-based payment modifier or meaningful use based on the specificity of diagnosis codes as long as they use a code from the correct ICD-10 family of codes. Penalties will not be applied if CMS experiences difficulties calculating quality scores for these programs as a result of ICD-10 implementation.
  • Payment disruptions. If Medicare contractors are unable to process claims as a result of problems with ICD-10, CMS will authorize advance payments to physicians.
  • Navigating transition problems. CMS has said it will establish a communication center to monitor issues and resolve them as quickly as possible. This will include an “ICD-10 ombudsman” devoted to triaging physician issues.

Free help solutions include “Road to 10” primers aimed at smaller physician practices with clinical documentation, clinical scenarios, and other specialty-specific resources to help with implementation, as well as training videos for other helpful tips.

See also ICD-10 Guidance to help you get ready for ICD-10.

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