Transitions aren’t always easy. And as the mother of a young daughter, I’m more than familiar with the frustration and tantrums that can come as a result of change. But as professionals in the healthcare industry, we don’t have time for tears or frowny faces—especially when it comes to ICD-10. With under two months to go before the big transition, there’s no room for meltdowns; we need to put our heads down and take on the change swiftly and confidently. That’s because there’s truly something to be said about “ripping off the Band-Aid”; it’s simply less painful that way. But CMS and the AMA think differently: they’ve adopted a slower and more painful approach to tackling the transition. According to their recent announcement, during the 12 months immediately following the October 1, 2015, date, “Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family.”
What Does that Really Mean?
If you think this announcement means that Medicare will forgive all your ICD-10 coding sins, you could be in for a rude awakening. After all, while the 12 months of claim-denial flexibility might seem like a saving grace on the surface, you have to ask yourself: what is it really saving us from? Not a thing. Whether you learn how to code properly now—or 12 months from October 1—the results are the same: if you can’t successfully make the transition, payers will deny your claims. And this “grace period” is not your free pass to kick the ICD-10 can down the road. You still must transition to ICD-10, and—more importantly—you still must make an effort to code to the highest level of specificity. Furthermore, this "grace period" is for Medicare claims only. Third-party payers have yet to implement any type of one-year transition period.
Is Your Practice Safe?
Speaking of coding to the highest level of specificity, you’ve got to consider what errors this grace period actually permits. Here’s what you need to know:
Date of Service
For all HIPAA-covered entities, you must submit ICD-10 codes for all dates of service on or after October 1, 2015. This date is non-negotiable, and all payers will deny your claims if you use ICD-9 codes for dates of service on or after October 1. As for non-HIPAA-covered payers, you’ll need to contact each one directly to determine whether it plans to adopt ICD-10.
Even with Medicare's grace period ruling, you still must use a valid code within the correct family of codes. So, if your coding selection majorly misses the mark, you’ll receive a denial. But if you make a mistake and still land within the correct family of codes, there’s a good chance Medicare will reimburse the claim.
This shouldn’t come as a surprise, but if your claims contain both ICD-9 and ICD-10 codes for any dates of service on or after October 1, you will not receive payment. That said, you’ll have to pay extra close attention to any claims that span the transition date. In those cases, split your claims—and be sure to check with your payers to find out how they prefer you to handle split claims.
What Should You Do to Prepare?
First, I suggest moving forward as if the grace period weren’t happening. If you absolutely need it, it’s there for you. But the sooner you’re totally ICD-10-ready, the sooner the stress of the transition will be behind you. Why not put in the extra work now and make sure you’re able to find the right code every single time—starting with your first claim submission? To make the preparation process easier for you, this month we’re covering everything you need to know about ICD-10 right here on the WebPT Blog. We’ve also created the Physical Therapist’s Crunch-Time Guide to ICD-10 for you to download and use completely free of charge. And if you’re looking for even more awesome (and awesomely free) information, be sure to check out ICD10forPT.com and this month's webinar, co-starring ICD-10 expert Rick Gawenda.
Whether your prefer Band-Aids with Hello Kitty designs or water-blocking plus technology, slowly pulling them off isn’t going to ease the pain of transitioning to ICD-10—and neither will the grace period. With that in mind, I urge you to keep your chin up and move forward to take on all the changes that lie ahead with a no-fear, can-do attitude.