The final milestone on the road to implementing ICD-10 (International Classification of Diseases, 10th revision) is drawing near. The 12-month grace period is scheduled to end as of Oct. 1, 2016, but that date will most likely pass with little notice, because implementation appears to have gone well since Oct. 1, 2015.
“On average, it seems the ICD-10 transition was seamless across the board in rheumatology practices,” says Antanya A. Chung, CPC, CPC-I, CRHC, CCP, director of practice management at the ACR. “There were a few hiccups here and there, but mainly on the payer side.”
After the grace period ends, some physicians may see an increase in denied claims, but the Centers for Medicare & Medicaid Services (CMS) recommends auditing key performance indicators (KPIs) to quantify how well their ICD-10 implementation has gone to date and ensure smooth sailing going forward.
Grace Period Approved, but Forgotten?
Mitigating burdens and risks of ICD-10 implementation has been a major focus of the ACR’s advocacy efforts over the past several years. The ACR worked with Rep. Diane Black (R-TN-06) to introduce H.R. 2247, which would create a safe harbor grace period upon implementation of ICD-10. The ICD-10 grace period, based in large part on this legislation, was met with approval by practicing physicians across the country in July 2015, when the CMS and the American Medical Association (AMA) made the joint announcement. The CMS’ guidance ensured that claims would not be denied solely because of a lack of specificity as long as physicians used “a valid code from the right family of codes,” referring to the ICD-10 three-character category headings. Because this flexibility was true only for claims submitted to CMS, many practices chose to implement ICD-10 fully from the get-go.
“I’m not sure if most people remember there was a grace period and that it is ending,” Ms. Chung says. “So much is going on daily, but we hope rheumatology practices have been coding to the highest level of specificity so that there will be no disruption for them on Oct. 1. In our training classes last year, we emphasized that while CMS gave a one-year grace period, other third-party payers were not obligated to do so, [which is why] it was important to code the patient’s visit correctly the first time; [we want to avoid] retraining when the grace period goes away. I believe that our membership took heed of the advice and will once again see a seamless changeover for the new 2017 diagnosis coding year.”
The Toolkit
In addition to the work that practices have done to date, there are other ways to help protect against practice disruptions after Oct. 1, 2016. One resource is the CMS ICD-10 Next Steps Toolkit.
The primary recommendation in the toolkit is to measure KPIs, such as claims acceptance/rejection, coder productivity, payer edits, or incomplete or missing diagnosis codes. The purpose of tracking and comparing these and other KPIs is to identify and correct any problems with productivity, reimbursement or claims submission. Tips include tracking KPIs separately for each payer and comparing metrics over calendar years to account for seasonal fluctuations.
With careful planning and attention to detail, the expectation is that the end of the grace period will go unnoticed.
Kimberly J. Retzlaff is a freelance medical journalist based in Denver.
