ICD-10 Transition Date Finalized for October 2015

The Centers for Medicare and Medicaid Services announced last week that the final deadline to comply with the ICD-10 implementation requirement is October 1, 2015. The tenth edition of the International Classification of Diseases is widely viewed as a significant change in the way claims that are submitted to Medicare and private insurance payers are classified. 

These changes enable providers to coordinate patients care over distance and time, improve the accuracy of patient records with more detailed patient history coding, and reduce fraudulent claims. CMS also believes that the ICD-10's granular classifications will improve the data and analytics related to public health research, surveillance, and reporting. The more specific classifications found in ICD-10 represent, in part, the evolution of diagnosis and the modern developments in medicine and medical technology used to treat patients. 

CMS released an online resource designed to help providers in small practices make a timely transition to ICD-10. The "Road to 10" is an online resource available here. The  Road to 10 breaks allows providers to select a profile based on their expertise that is specifically tailored to each speciality's common codes, clinical documentation procedures, and clinical scenarios. Additionally, the Road to 10 gives users the opportunity to create an ICD implementation action plan specifically suited to the needs of their small practices. 

ICD-10 Deadline Delay Slows Medical Billing Conversion

Medical billing codes are used by doctors, hospitals, and health insurance companies to track each patient procedure and ensure that the doctors are paid. The ICD-9 code has been in place since the 1970s. The ICD-9 was scheduled to be replaced with ICD-10 by October 2014. 

The conversion would add tens of thousands of unique codes to the medical billing structure, an increase to roughly 72,000 codes in ICD-10 from about 4,000 codes in ICD-9. Advocates for ICD-10 argue that the new coding system is necessary to modernize the billing code to capture the variety of medical treatments available now that did not exist in the 19070s.  Additionally, they argue that a more detailed code will allow for more precise medical research and data collection. 

Despite the benefits of moving to an ICD-10 medical billing system, the transition over the last five years has been difficult. In order for the transition to be smooth and successful all parties need to switch to the ICD-10 codes at the same time. Many smaller practices were not able to dedicate the training time and resources to complete the transition by October of this year. 

However, larger facilities, hospitals, and insurance companies with more resources were able to dedicate time and money to implementation measures and preparation. In fact, many have spent millions to train staff on the new ICD-10 billing codes. These facilities were relying on the statements by Health and Human Services representatives made as late as February 2014 that explained the October compliance date was firm. Questions remain about the implementation of ICD-10 at these facilities and whether these employees will need to be re-trained as the adjusted ICD-10 deadline nears.

CMS Issues Guidance on Stage 2 Meaningful Use Hardship Exceptions

The Centers for Medicare and Medicaid Services (CMS) issued guidance on qualifying for the hardship exception from Stage 2 meaningful use requirements under the federal electronic health record incentive payment program. CMS has been under pressure by stakeholders and lawmakers alike to provide clarification about how to apply and what conditions qualified hospitals and eligible professionals for a hardship exemption

The guidance explains that CMS may grant hospitals and eligible professionals the hardship exception and grant an extension for meeting the Stage 2 meaningful use requirements if their electronic health record (EHR) vendor is at fault for their failure to meet the deadline. This expands on previous statements by CMS Administrator Marilyn Tavenner that the applications for exceptions would be evaluated on a case-by-case basis. 

The guidance specifically states that providers may apply for hardship exceptions if the "EHR vendor was unable to obtain 2014 certification" or the hospital or eligible professional "was unable to implement meaningful use due to 2014 EHR certification delays." If approved, the hardship exception is valid for a single payment year. In the event the application for exception is denied hospitals and eligible professionals may not appeal the decision and any denial is considered final.

The hardship exception application for hospitals is available here.

The hardship exception application for eligible professionals is available here. 

No Extension for ICD-10 Implementation

Marilyn Tavenner, Administrator for the Centers of Medicare & Medicaid Services, announced today that there will be no extension of the October 1, compliance deadline for the nationwide conversion to the ICD-10 diagnostic and procedural codes. Speaking at the Healthcare Information and Management Systems Society convention in Orlando, Florida, Tavenner also explained that CMS was not changing compliance requirements for Stage 2 despite extensive pressure on the agency. 

Stage 2 of the electronic health record incentive payment program requires providers to electronically exchange healthcare records with each other to improve the interoperability of CMS' value-based payment programs. Eligible hospitals must commence 90 consecutive days of meeting the meaningful-use criteria on schedule. The starting date for most hospitals was October 1, 2013. However eligible professionals and physicians which operate on a fiscal year must begin compliance on April 1 or July 1, 2014. 

CMS will consider extensions on a case-by-case basis for providers and health IT vendors to obtain a "hardship exemption" that will extend the deadline for that facility. Tavenner does not expect the exemptions to delay full Stage 2 implementation by 2015.