With less than one month to go until the Oct. 1 deadline, it’s a race against the clock for U.S. healthcare providers to transition to the 10th version of the International Classification of Diseases. In the coming weeks, hospitals and ambulatory surgery centers will make final preparations for the coding switch, implementing last-minute updates to processes and systems and, in many cases, shoring up financial reserves to avoid cash flow disruptions.
Troubleshooting, in particular, is expected to be a priority for providersin the days before the go-live date, as many facilities appear to have saved testing, technical fixes and upgrades for the 11th hour. According to an American Health Information Management Association provider survey released in June, while 81 percent of respondents planned to conduct end-to-end ICD-10 testing, as of early summer, only 50 percent of providers had actually conducted test transactions using ICD-10 codes with payers and clearinghouses. Even more, just 34 percent had conducted internal testing and 17 percent had completed external testing as of early summer 2015.
As with all disciplines, practice makes perfect in revenue cycle management; the more time facilities spend testing and identifying areas for improvement, the fewer disruptions – cash flow and otherwise -- they can expect to see after the deadline. The following best practices can help ASCs troubleshoot the most critical aspects of the revenue cycle ahead of the ICD-10 transition and avoid financial disruptions:
Vendor delays appear to be at least partly to blame for the last-minute ICD-10 scramble this summer. In a March 2015 letter to the U.S. Department of Health and Human Services, the Workgroup for Electronic Data Interchange wrote that about one-third of healthcare software and services vendors it surveyed were still not ready for ICD-10 customer testing or usage. The health IT trade group also told regulators in the letter that one quarter of the vendors it interviewed indicated that updates would remain unavailable until at least the second quarter of 2015.
For small providers and facilities, in particular, these ICD-10 software update delays only heighten the importance of conducting rigorous testing and troubleshooting in the time remaining. Still, panic has yet to set in: In its June survey,AHIMA reported that only half of small providers had “performed technical system upgrades/updates to support ICD-10,” while more than three-quarters of large organizations had done so as of early summer 2015.
With limited time between now and Oct. 1, providers should complete an inventory of every piece of software utilized at their facilities, inquire with the appropriate vendors about ICD-10 updates, and deploy and test the releases as soon as possible.
As with all software, bugs are often inevitable. And these predictable glitches only underscore the importance of troubleshooting as soon as possible, so that patches can be obtained and deployed, if necessary. Facilities may also encounter additional costs in updating these systems, and outside IT consultants may be required to implement the updates.
Provider preparedness appears to be highest when it comes to the coding staff readiness. According to the June AHIMA survey, roughly 70 percent or more of all providers had distributed to staff ICD-10 awareness and educational materials, assessed readiness internally and prepared for implementation, and provided ICD-10 staff training.
Providers can take advantage of this head start by requiring staff to code in both ICD-9 and ICD-10 between now and Oct. 1. Dual coding allows managers to troubleshoot potential problems and identify areas for improvement well before they become a costly mistake.
Delayed reimbursement has been a major source of heartburn for ASCs and other providers heading into the deadline. That’s why providers breathed a collective sign of relief in July, when CMS announced it was softening its stance on claims denials for Medicare until 2016, promising not to hold up reimbursements if coders use the correct ICD-10 family code.
“While diagnosis coding to the correct level of specificity is the goal for all claims, for 12 months after ICD-10 implementation, 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,” CMS wrote in published guidance.
As of press time, it was uncertain whether major commercial payers would follow Medicare’s lead and implement a similar coding grace period. With that in mind, ASCs and other providers should assume Oct. 1 is a hard-and-fast deadline for the ICD-10 transition, especially for major payers that appear to be well prepared for the ICD-10 transition.
As of winter 2015, about 80 percent of health plans surveyed had started internal ICD-10 testing, according to WEDI. In addition, more than half also had begun external testing by last February, while 40 percent expected to start by July 1.
Yet, smaller regional payers may still require ICD-9 codes after the deadline, so it’s important to follow-up with all familiarhealth plans about possible last-minute policy changes that may result in reimbursement delays or claims denials down the road.
CMS is offering a variety of ICD-10 testing programs that allow providers to troubleshoot various aspects of their revenue cycles in the run-up to the fall deadline. The agency conducted three separate end-to-end volunteer testing opportunities in 2015 that allowed providers to successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems, adjudicate claims appropriately using CMS software updated for ICD-10, and produce accurate RAs.
While the last CMS end-to-end testing period concluded in July, providers may still utilize acknowledgement tests to troubleshoot their systems through the Oct. 1 deadline. This helpful, simple tool allows providers to submit ICD-10 codes and receive acceptance – or denial – confirmation from Medicare’s Fee-For-Service claims systems.
Your ASC’s accountant will thank you for it later.
This guest column is the second in a series on ICD-10 readiness, troubleshooting and solutions. Please look for the final installment in the next issue of Becker's ASC Review.