A Delay for ICD-10– Now What?

A one-year delay in ICD-10 implementation brings up many questions for doctors and health-care organizations.

Donna McCune, CCS-P, COE, CPMA
8/6/2014

Q. When did Congress announce the delay in ICD-10 implementation?

A.
On April 1, 2014, the Protecting Access to Medicare Act of 2014 (Pub. L. No. 113-93) was enacted, which said that the Secretary of Health and Human Services may not adopt ICD-10 prior to October 1, 2015. The delay was met with mixed reviews. The American Medical Association applauded the decision, citing the numerous regulatory burdens currently affecting physicians. The American Academy of Procedural Coders and the American Health Information Association encouraged physicians to stay the course and continue to prepare despite the delay.


Q. Was there also a delay in implementing the new Centers for Medicare & Medicaid Services 1500 form that provides increased “space” for ICD-10 codes?

A.
No; version 02/12 of the CMS 1500 form replaced version 08/05 on January 1, 2014, with required use as of April 1, 2014. The new form contains additional space for reporting more diagnosis codes and increases the space for diagnosis codes of up to seven digits, which will be required for ICD-10. The new form also adds “qualifiers” for ordering, referring and supervising physicians in Box 17. Additional information on the new form can be found at nucc.org.

Q. Will CMS continue to update ICD-10 files on its website?

A.
Yes. The 2015 General Equivalence Mapping files are currently available on the CMS website at cms.gov/Medicare/Coding/ICD10/2015-ICD-10-CM-and-GEMs.html. In addition, the 2015 ICD-9 and ICD-10 files are also posted on the CMS website.

Q. Will new codes continue to be created?

A.
ICD updates are effective October 1 of each year. However, CMS recently published information on a code set “partial freeze” for ICD-10; it notes that ICD-9 will also be affected. The CMS posting states the following:

• On October 1, 2014 there will be only limited code updates to both the ICD-9-CM and ICD-10 code sets. This is to capture new technologies and diseases as required by section 503(a) of Pub. L. 108-173.

• On October 1, 2015, again there will be updates only as noted above. There will be no updates to ICD-9-CM, as it will no longer be used for reporting to HIPAA-covered entities.

• On October 1, 2016, one year after the new scheduled implementation of ICD-10, regular updates to ICD-10 will begin.

In a separate posting, CMS stated that there will be no new, deleted or revised ICD-10-CM codes for 2015.


Q. Will CMS conduct additional front-end testing?

A.
Yes. CMS had planned a testing week in July 2014. This testing was cancelled due to the delayed implementation of ICD-10. CMS expects to conduct end-to-end testing in 2015; watch the CMS website and your local Medicare contractor websites for further details.


Q. Was the March 2014 end-to-end testing successful?

A.
It was. CMS reports that testers submitted more than 127,000 claims with ICD-10 codes to the Medicare fee-for-service claims system and received electronic acknowledgement that their claims were accepted.
Nationally, CMS showed an 89-percent acceptance rate for ICD-10 codes, which they considered a successful result. CMS also noted that some claims were purposely submitted with errors to test that errors would be identified.


Q. Is it a worthwhile exercise to familiarize myself with the existing ICD-10-CM Manual?

A.
Definitely. There are many new concepts presented in ICD-10. The ICD-10-CM Manual contains four more chapters than ICD-9 and the number of code choices increases from 14,000 to 69,000. The guidelines published in the beginning of the manual are extremely instructive and provide a review of ICD-9 guidelines as well as introduce some subtle changes to coding with ICD-10.


Q. Should I continue to train my staff during this delay?

A.
This is a great opportunity to better prepare them for ICD-10. Non-clinical staff will benefit with additional training on medical terminology and anatomy of the eye. The specificity of ICD-10 requires a higher-level understanding of ophthalmology for proper code selection.

Technicians and scribes can improve their documentation, especially with history taking. A fair amount of information required for proper ICD-10 code selection will come from the patient’s history.


Q. Is there any value in practicing our ability to select an ICD-10 code?

A.
Yes. By beginning to dual-code some encounters with ICD-10 codes, you will reveal vulnerabilities in your chart documentation that make code selection difficult or impossible. In addition, the more familiar you and your staff become with the manual, the less intimidating it will be in October 2015.  


Q. Are some ophthalmic diseases coded differently in ICD-10 than ICD-9, and will this necessitate a change in my current documentation?

A. Yes, there are several. Glaucoma is a good example of a disease that is coded differently. Many physicians are lax with documenting the stage of glaucoma in a patient’s medical record. Currently, few payers, if any, will deny a claim that does not contain the ICD-9 stage code. With ICD-10, your ability to select a code for glaucoma will require that the disease stage be documented.

For example, when coding appropriately for glaucoma with ICD-9 codes, the type of glaucoma is one ICD-9 code and the stage of glaucoma is a second ICD-9 code. A patient with primary open-angle glaucoma, moderate stage, is coded as 365.11 for the POAG and 365.72 to describe the moderate stage. In ICD-10, the stage is added to the ICD-10 code for POAG as a seventh digit. POAG, moderate stage in both eyes, is coded with one code in ICD-10, H40.11x2.

Physicians currently not documenting the stage of glaucoma should begin to stage the glaucoma now so that it is not a burden when ICD-10 coding begins.


Q. What other documentation changes should we consider making?

A.
Because ICD-10 codes are more specific than ICD-9, there are many changes you can begin to implement.

1. Are your assessments as specific as possible? For example, if you note a corneal ulcer in your impression, are you indicating whether it is a central corneal ulcer, or a marginal ulcer or a perforated corneal ulcer?

2. Are your assessments specific to which eye or eyelid? For example, do you note in the impression if the patient has a chalazion on the left lower or left upper lid as opposed to just noting chalazion? Is the patient’s nuclear sclerotic cataract in her right eye, left eye or both eyes?

3. For patients with a systemic disease and an ocular manifestation, are you indicating both the disease and the manifestation in the impression?

Improved documentation in the impression will facilitate more efficient selection of ICD-10 codes. It is not too soon to begin to make these changes in your current medical records.


Q. Should we wait on ICD-10 and begin to prepare for ICD-11?

A.
No. ICD-11 only exists in draft form and is not expected until 2020 or 2025.   REVIEW


Ms. McCune is vice pres­ident of the Cor­coran Con­sult­ing Group. Con­tact her at DMcCune@corcoranccg.com.