Why ICD-10 Codes Must Tell Your Patient’s Story

By Amanda Patton, ACCC Communications

We’re four months post ICD-10 implementation and some are comparing the transition to Y2K—a lot of sound and fury over what ultimately turned out to be a relatively calm transition.

If you think it’s all smooth sailing from here on out, think again. “ICD-10 is nothing like Y2K,” says Cindy Parman, CPC, CPC-H, RCC, Principal, Coding Strategies, Inc. “Moving to ICD-10 is more like having a baby. Once the baby’s arrived the work begins.”

In a session on Friday, March 4 at the ACCC 42nd Annual Meeting, CANCERSCAPE, Parman will be sharing tips for cancer programs to take stock of their ICD-10 transition.

Post implementation, what ICD-10 pain points is Parman seeing in oncology programs?

· Coding errors.  These may be coder mistakes or they may stem from insufficient documentation in the medical record—for example, physicians not providing enough information.
· Productivity.  Working with ICD-10 is taking coders longer because there is more information to sift through and coders may have to go back to physicians with questions.
· Reimbursement issues.  Insurance payers are taking an opportunity to tighten up qualifications for reimbursement. Some ICD-9 codes may have been reimbursed in the past, where the corresponding ICD-10 code will not result in payment. Even smooth transitions to ICD-10 don’t necessarily mean that cancer programs are coding correctly, Parman warns.

“It’s important for cancer programs to understand that ICD-10 is a patient classification system,” says Parman. Used appropriately, the code set will generate the data that tells the patient’s story and ensure that providers are getting credit for all of the care that is being provided. But when codes are missed that story is incomplete.

New payment models will be driven by ICD-10 codes, and capturing all the care provided for patients is critical, Parman says. “The data that cancer programs are collecting today will be used by the Centers for Medicare & Medicaid Services (CMS) to develop future alternative payment models (APMs). If the codes used do not reflect the full scope of services provided, cancer programs won’t be able to go back later and say ‘we left these codes off.’ ”

During her meeting session, Parman will discuss the potential for mining ICD-10 data to measure quality, safety and efficiency, among other indicators. But, she points out, “You can’t mine data you don’t have.”

Join us at the ACCC 42nd Annual Meeting, CANCERSCAPE, from March 2—4, 2016, in Washington, D.C., and gain strategic insight into three key drivers of change impacting our evolving oncology care delivery system: policy, value, and quality. Full session and speaker information available here.

ICD-10-CM Delay: What Next?

by Amanda Patton, Manager, Communications, ACCC

The language delaying implementation of ICD-10 that was piggy-backed on last week’s SGR “patch” legislation caught many off guard. With months—if not years—of preparation and planning for implementing the new code set—it seems we’re back to uncertainty. ACCCBuzz asked Cindy Parman, CPC, CPC-H, RCC, to share her thoughts on the delay and next steps for cancer programs. Parman is a principal at Coding Strategies, Inc., and authors the “Compliance” column for ACCC’s journal, Oncology Issues.

ACCCBuzz: What are your thoughts on this latest delay by Congress?

Parman: First, it isn’t over until it’s over. The Centers for Medicare & Medicaid Services (CMS) has not weighed in yet [at the time this post was written] on what the inclusion of ICD-10 delay language in the SGR fix legislation really means. At present, several news sources have suggested that the agency’s silence on the never-ending drama—termed by one publication as “ICD-10 Held Hostage”—could mean:

1. There will be an official implementation delay until October 1, 2015, or
2. CMS will establish a different mandatory/voluntary implementation scheme, or
3. CMS will decide to allow those providers who want to voluntarily implement ICD-10 on October 1, 2014, to do so, or
4. CMS will decide that the legislation is not valid, since there was no Federal Register announcement, no comment period, etc., and
5. Other payers may decide to “go live” on October 1, 2014, regardless of the SGR patch legislation that affects only the Department of Health & Human Services (HHS).

ACCCBuzz: Assuming that ICD-10 implementation is delayed, what does that mean for hospitals and physician groups who have already invested in computer system upgrades, clinical documentation improvement, and coding education?

Parman: According to the American Health Information Management Association (AHIMA) in a March 31, 2014, email to its membership:

Effects of a one year delay include an estimated likely cost of $1 billion to $6.6 billion to the healthcare industry and lost opportunity costs for failing to move to a more effective code set. A cloud will also be cast over the employment prospects of more than 25,000 students who have learned to code exclusively in ICD-10 in HIM associate and baccalaureate educational programs.

ACCCBuzz: So what should oncology providers do now with respect to the ICD-10 transition?

Parman: It’s important to stay the course. Shelving the work completed so far and losing the financial investment is simply not an option! Here are some tips to help:

• Keep working on clinical documentation improvement (CDI). This is not just a project that affects ICD-10; it affects quality reporting, value-based modifiers, responses to audits and investigations, patient portals, and almost every other aspect of healthcare. Practices and facilities who have not implemented a CDI program should get the ball rolling as soon as possible. (Find out more about why you need a CDI program here.)
• Know the ICD-9-CM Official Guidelines for Coding and Reporting! The ICD-10-CM Official Guidelines include some changes to sequencing, mandatory assignment of additional diagnosis codes for tobacco and alcohol use, etc., but they are built on the same format and structure. As a compliance consultant that performs both radiation oncology and infusion center chart audits, I rarely see correct and complete ICD-9-CM diagnosis coding. If a facility or practice is completely documenting all primary, secondary, and tertiary medical conditions with ICD-9, the transition to ICD-10 will be so much easier.
• For those providers who have initiated or completed training on the ICD-10 code set, it is use it or lose it. Make certain that coding staff continues to use the ICD-10-CM code set, by dual-coding a subset of medical records, performing peer review of records coded with ICD-10, etc. Do something creative, like a weekly Lunch-and-Learn to discuss unique ICD-10 coding situations.
• For those providers who have not initiated or completed training on the ICD-10 code set, don’t wait – just do it. The whole point of any transition delay is to maximize the remaining time to complete the task. This is a larger coding classification than ICD-9-CM with variances in the verbiage and specificity of available codes. Don’t underestimate the extent of education required, and don’t wait until the last minute and assume that there will be training programs available.
• Continue to perform end-to-end testing with those payers who are ready for this. Test often with any payer that is available for testing, and set up a process for denial management. There is a potential for an increased number of denials with the implementation of ICD-10, so make sure your denial management process is efficient and accurate. Of course, the best way to manage denials is not to have any, so use this gift of time to also improve front-end processes to minimize rejections and denials.
• Facilities who have completed the computer system updates, clinical documentation improvement, and most or all of the coding education can consider “backtrack” diagnosis coding. This means that the medical coding staff reports ICD-10-CM diagnosis codes, but the software backtracks and bills the ICD-9-CM code. This is a much easier conversion process (to go from one detailed code back to a more general diagnosis code) and can be accomplished by many existing billing software engines. If this process is initiated during calendar year 2014, the actual transition to ICD-10, when it finally occurs, may be smooth and straight-forward.

ACCCBuzz: What about those who say, “Why not just wait for ICD-11?”

Parman: Have you seen ICD-11? It is built on ICD-10, so be careful what you wish for! Attempting to transition from the ICD-9 classification directly to ICD-11, and bypassing ICD-10, will create additional stress (economic, financial, and mental), especially for intermediate and small physician practices.

The World Health Organization (WHO) plans to release the ICD-11 classification somewhere between 2015 and 2017 (depending on which WHO document you read).  Not only will ICD-11 incorporate all the functionality of ICD-10, it will be digital only (no paper manuals) and will link with terminologies such as SNOMED CT (Systematized Nomenclature of Medicine – Clinical Terms) and support electronic health records and information systems. Remember that a WHO “release” as early as 2015 still means that various agencies and committees will have to meet and develop the Clinical Modification (CM) that will be used in the U.S.

ACCCBuzz: Any parting advice?

Parman: Use any implementation time resulting from a delay in ICD-10 transition to improve operations, documentation integrity, and coding skills. Never waste the gift of time!

Editor’s Note: ICD-11 release date in this post was updated 4/14/14 to reflect ambiguity in the current WHO timeline.

 

ICD-10: Ready or Not?

by Amanda Patton, Manager, Communications, ACCC

While the granular detail offered by ICD-10 may seem daunting and even excessive—as highlighted recently in the Washington Post’s Wonkblog,  “When Squirrels Attack! There’s a Medical Code for That”—the move has been a long time coming. (Implementation was originally scheduled for 2008 and has been postponed twice.)

All signs suggest that this time, the Centers for Medicare & Medicaid Services (CMS) is not going to blink. The agency says ICD-10 implementation is on course for Oct. 1, 2014.

Last week, CMS Administrator Marilyn Tavenner, addressing the American Medical Association’s National Advocacy Conference, urged physician practices to volunteer for “end-to-end” testing.

In its MLN Matters series, the agency said it will offer some testing services in May and full end-to-end testing to a small sample group of providers in late July.

With Oct. 1 just a little more than six months away, ACCCBuzz talked to Oncology Issues’s Compliance columnist Cindy Parman, CPC, CPC-H, RCC, about what cancer centers  should already have crossed off their “To Do” list and what still remains to be done.

What should be done by March 2014?

Parman: At this point, cancer centers should have:

• Completed awareness training (the “ready or not, here it comes” session) and selected a cross-functional implementation team. Ideally, you have a “champion” or “champions” who will lead the transition to ICD-10:

-A physician champion taking the lead on documentation improvement

-An  IT champion for software issues

-A medical coder champion to be an onsite expert, etc.

• Finished the gap analysis and workflow review, and established a plan to make changes where necessary. (You may have needed to re-think how diagnosis codes are currently assigned and which personnel should be performing the medical coding.)

• Identified all systems that will be impacted and prioritized these for software and/or hardware upgrades.

• Reviewed physician documentation and scheduled education for documentation improvement. Ideally this education has already started or even been completed—you don’t have to wait until ICD-10 is fully implemented!

• Set up an initial budget to include all transitional costs and established a training plan.

What do cancer centers needs to focus on between March and October 1, 2014?

Parman: Centers need to:

• Continue to pay attention to complete and accurate medical record documentation.

• Keep up ongoing communication with internal and external vendors to ensure that end-to-end testing is completed and any issues detected during testing are addressed immediately.

• Revisit and revise the budget for system upgrades, coding education, etc., as needed to account for any unexpected costs.

• Implement your previously established training plan to ensure that the cancer center has enough trained medical coders or other personnel who can accurately assign ICD-10-CM codes following the guidelines for this code set. Some facilities are performing “dual coding” (both ICD-9-CM and ICD-10-CM) to determine if there will be a need for temporary staff to help out during the months immediately following the transition.

• Review Medicare Local Coverage Determinations (LCDs) and other payer policies to determine any updates in medical necessity criteria, payer requirements for diagnosis codes, etc.

Then, you can sit back and know your center is prepared for the biggest change to the diagnosis coding classification in decades!

Resources for ICD-10 implementation are available on the American Health Information Management Association (AHIMA) website here.