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:

• ICD-10 Quick Start Guide
• CMS’s “Road to 10” (tool to create customized action plans)
• CMS’s main site 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.