Download pdf - ICD-10 Delay

ICD-‐10 Delay Wednesday, January 29, 2014

Disclaimer: Nothing that we are sharing is intended as legally binding or prescrip7ve advice. This presenta7on is a synthesis of publically available informa7on and best prac7ces.

•  1893 -‐ Ber7llon Classifica7on of Causes of Death •  1900 -‐ Interna7onal Classifica7on of Causes of Death •  Version 6 Interna7onal Sta7s7cal Classifica7on of Diseases,

Injuries and Causes of Death •  1948 -‐ The World Health Organiza7on assumed

responsibility to maintain •  1975 -‐ adopted the 3 character classifica7on to maintain

some consistency -‐ Interna1onal Classifica1on of Diseases •  Many modifiers and adapta7ons along the way •  1992 -‐ ICD-‐10 was published •  2017 -‐ ICD-‐11 will be published

ICD History

•  The ICD-‐10 code sets are NOT simply increased and renumbered ICD-‐9 code sets.

•  The ICD-‐10 code sets include greater detail, changes in terminology, and expanded concepts for injuries, laterality, and other related factors.

•  The complexity of ICD-‐10 provides many benefits because of the increased level of detail conveyed in the codes

– American Medical Associa1on

What is ICD-‐10

How ICD-‐10 Differs from ICD-‐9

•  Protec1ng Access to Medicare Act (H.R. 4302) •  “DOC FIX” -‐ The Sustainable Growth Rate (SGR) was set to reduce

Medicare physician payment rates by 24% on April 1, 2014. •  SGR was set by the Centers for Medicare and Medicaid Services

(CMS) to control Medicare spending on physician services.

•  Congress introduced "doc fix" included a provision to delay the ICD-‐10 compliance date to October 1, 2015.

•  The House passed the bill to postpone the SGR and delay ICD-‐10 on Thursday, March 28, 2014, and the Senate passed the same bill on Monday, March 31, 2014.

The ICD-‐10 Delay

What does this mean....

The Good: • Our clients don't need to undertake the financial hit of ICD10 while also absorbing the reduced Medicare fee schedule and the Affordable Care Act (which is leading to higher pa1ent pays and Medicaid enrollment). The Bad: • Everyone must s1ll upgrade this year on all EHRs. The 2011 cer1fica1ons expired on 12/31/13 and new 2014 cer1fied systems are needed for both MU1 and MU2. Clinics should be looking to upgrade now and ahest no later than Q3 (or look into the new hardship exemp1ons). To sum it up: • ICD-‐10 delay at this point is a good tac1c, but part of a bad strategy. If we are going to change the en1re landscape of healthcare, let’s do the sensible thing and spread it out over a period of years, not a period of months.

-‐Ben Quirk

Quirk Response

•  Retes1ng •  Training and implementa1on already set up •  Shortcuts that prevented more thoughkul changes in order to meet the

deadline •  Students in medical coding currently enrolled are preparing for ICD-‐10 and

some do not have ICD-‐9 exposure •  Budgeted expenses already allocated for execu1on •  May slow sales •  May delay upgrades •  The reduc1on of 24% in payments will increase if a permanent fix is not

implemented •  Many vendors have acted in good faith and invested significant

1me, energy, and resources to comply with the deadline. CMS es1mates that a one-‐year delay of ICD-‐10 could cost between $1 billion and $6.6 billion

Nega1ve Cri1cism of the Delay

•  Avoiding Cash Flow disrup1on…for now •  The Centers for Medicare and Medicaid Services (CMS) es1mates

that in early stages of implementa1on, denial rates will rise by 100 to 200 percent, and that days in accounts receivable will grow 20 to 40 percent.

•  Migra1on to ICD-‐10 carries a risk due to incomplete or inaccurate transla1on of exis1ng policies, benefits, and payment rules within payer systems.

•  Delays in payments can also occur because of challenges in claim processing in the ICD-‐10 environment.

•  Programmers look at it as a “longer runway” or 1me to “get it right” •  Others feel it is a good 1me to focus on MU2 and ACO programs •  Physicians avoiding up to a 24% reduc1on in re-‐imbursement rates •  Allocated funds can be invested as reserves and earn interest

Posi1ve Cri1cism of the Delay

•  Increased focus on clinical documenta=on improvement (CDI). s1ll a cri1cal component to quality repor1ng and improving cash flow.

•  Develop long-‐term coder strategy. Regardless of a delay decision, you will need a strategy to retain and incen1vize coders

•  Op=mize your revenue cycle performance. The delay provides an opportunity to perform a “deep dive” that will explore and improve exis1ng

•  Evaluate Computer Assisted Coding (CAC). You can use the delay to do a search and selec1on and evaluate how a CAC op1on can help achieve transi1on goals while reducing costs and increasing coder produc1vity.

•  Con=nue dual coding and training. The delay will provide you with more 1me to iden1fy poten1al risk areas/issues between ICD-‐9 and ICD-‐10 codes

•  Comprehensive system remedia=on & tes=ng. You now have 1me for a more comprehensive plan to ensure all IT systems and partners are capable of receiving and producing ICD-‐10 codes for billing and internal/external repor1ng purposes.

•  Focus on physician educa=on (employed and ancillary). It’s important that you con1nue as planned with CDI training for physicians. The addi1onal training will allow the physicians more 1me to both learn and adopt the increased documenta1on requirements.

-‐Beacon Partners

Posi1ve Cri1cism of the Delay

What the vendors are saying…

Prac1ce Fusion •  As a result of this one year delay, Prac1ce Fusion providers will not

be required to use ICD-‐10 codes in healthcare claims this year. However, ICD-‐10 is s1ll coming, so it’s important for all stakeholders in the healthcare industry to become familiar with ICD-‐10.

•  Prac1ce Fusion was prepared to help providers customers to meet the 2014 deadline, and despite the delay, we will con1nue to help our providers prepare well in advance of October 1, 2015. Keep on the lookout for more blog posts, webinars, in-‐product tools, and other educa1onal resources to help with the ICD-‐10 transi1on.

-‐Ryan Donovan | VP Corporate Communica1ons


Allscripts • The ICD-‐10 delay does not change Allscripts plans. We’ve informed our clients that everything is s1ll on schedule and have encouraged them to upgrade as they originally planned to ensure they’re prepared.

-‐Ariana Nikitas | Director of Client Communica1ons

-‐Russ Cobb | VP of Marke1ng and Communica1ons For the full statement, please visit: h4p://www.allscripts.com/en/resources.html


Greenway All I know is that we are in full deployment mode and nothing has changed on our side. We encourage clients to focus on exis1ng programs that create a strong founda1on for evolving and future value-‐based and alterna1ve payment incen1ve models, such as accountable care organiza1ons (ACOs) and pa1ent-‐centered medical homes (PCMHs).

-‐Jus1n Barnes | VP of Government Affairs


Athenahealth Guaranteed success with or without the delay or your money back. They feel like there are no impacts to their system. “It is unfortunate that the government has once again chosen to delay ICD-‐10. athenahealth and its clients are/were prepared for the ICD-‐10 transi1on, and in fact we have na1onal payer data showing that 78 percent of payers are currently proving readiness in line with the 2014 deadline.”

-‐Ed Parks|COO For the full statement, please visit: h4p://www.athenahealth.com/blog/2014/03/31/icd-‐10-‐dismay/