Today’s post comes from Tom Ambury, PT and compliance officer at PT Compliance Group, and WebPT cofounder and COO Heidi Jannenga, PT, MPT, ATC/L.
Note: Congress has passed legislation to delay ICD-10 implementation until October 1, 2015. Read the full story here.
Today, the ICD-10 implementation date is less than a year away. I know a year away can seem like a long time, but this will most likely be the major compliance initiative of 2014, so it’s good to be ready. With that in mind, let’s take a look at ICD-10, and hopefully I can provide you with some practical advice on how to prepare.
First, let me say that we therapists are not in this alone. This change from ICD-9 to ICD-10 will affect everyone who participates in the healthcare system. You see, when a patient is sent to physical therapy after October 1, 2014, the referral will have to have the new ICD-10 diagnosis. The therapist evaluating the patient will have to know what the diagnosis is and also, after evaluating, he or she must be able to describe therapy diagnoses in ICD-10 codes. Finally, the insurance provider processing the claim will need to be able to process the claim with the new ICD-10 diagnoses codes.
Second, there are exceptions. While complying with ICD-10 applies to virtually all HIPAA-covered entities, ICD-10 apparently does not apply to Workers Compensation, auto, and property and casualty insurers.
I can imagine that there are more than a few small providers out there who just haven’t had the time to look at what it will take to transition from ICD-9 to ICD-10. Or perhaps, they are simply relying on larger providers, hospitals, billers, or software vendors to help them with the transition—and they may help. However, it is important for all providers—big or small—to understand that the responsibility for transitioning to ICD-10 remains solely with each provider.
If you haven’t already begun planning for the ICD-10 conversion, you may be wondering when and where to start. Here are a few recommendations:
- Work backwards from the implementation date of October 1, 2014.
- Consider who needs training and the size of your staff. Some providers with a more specialized practice may have more ICD-10 codes to use; some may have fewer. An important note to remember: ICD-10 codes will be different from the ICD-9 codes you are accustom to using.
- Make sure you communicate with your outside vendors. They may be able to help you provide training for your staff.
- Establish timelines that allow for sufficient planning, training, implementation, and testing.
- Identify priorities, like dependencies on external vendors and internal processes.
- Include documentation requirements to justify the use of a specific ICD-10 code in your training. (The bottom line is that clinical documentation should capture the detail necessary to assign the new ICD-10 code.)
In addition to the above recommendations, here are four questions to test your readiness:
- If you had to select an ICD-10 code for the last patient, what would it be?
- Does the documentation for that patient describe the patient’s condition in sufficient detail to capture the use of that ICD-10 code?
- If you had to bill a claim with the ICD-10 code, how would you do that?
- If you received a claim rejection for an incorrect, invalid, or incompatible ICD-10 code, how would you correct that?
As a note, third-party billers cannot convert ICD-9 to ICD-10 codes for you because they do not have the clinical documentation to make the appropriate code selection.
Ultimately, the key to a smooth transition is being prepared. So start by taking advantage of the trainings available through WebPT and CMS. Then, begin the conversations with your vendors and staff to determine what each will do to facilitate the transition and by when. Finally, be prepared to test the new codes and your internal processes before October 1, 2014, so you can identify any bugs, make corrections, and provide additional training for you and your staff.
Have questions about your clinic’s readiness? Ask them in the comments section below.