ICD-TEN Act Ensures Reasonable, Responsible ICD-10 Transition
By - The ICD-10 implementation deadline is up for review with the recent push for a new bill from Representative Diane Black (R-TN) and the House of Representatives – the Increasing Clarity for Doctors by Transitioning Effectively Now Act (ICD-TEN Act). The ICD-TEN Act is part of a recent series of ICD-10-based bill proposals from the House, including the Protecting Patients and Physicians Against Coding Act of 2015 (H.R. 2652), which seeks a two-year ICD-10 “grace period” without denials.
Calling for an 18-month “safe harbor” period and full end-to-end testing from the Centers for Medicare & Medicaid Services (CMS), the ICD-TEN Act (H.R. 2247) ensures a “reasonable and responsible” ICD-10 transition, states the American College of Rheumatology (ACR). This physician group confirms zealous support for the ICD-TEN Act and was actively urging representatives to co-sponsor H.R. 2247 last month on Capitol Hill. ACR claims the ICD-TEN Act will ensure a seamless ICD-10 transition.
“While a coding system may be out of the public spotlight, it has vast implications for physicians and the quality of care administered to our patients," states Will Harvey, MD, MSc, FACR, Government Affairs Committee Chair of the ACR and practicing rheumatologist at Tufts Medical Center, in ACR’s press release. “A well-functioning ICD-10 system is crucial to accurate diagnosis, disease tracking, and quality improvements. And so as we embark on this transition, it is vital that we do so in a way that allows providers to continue focusing their time on patient care, while giving them a practical and clearly defined window of time to adapt to the new changes,” he explains.
Harvey confirms the healthcare system has essentially functioned for the past 36 years on the outdated ICD-9 codes. “Giving providers 18 months to transition effectively to the new code set is both fair and reasonable given the magnitude of this undertaking.” Harvey maintains.
In light of the ACR's legislative perspective, RevCycleIntelligence.com spoke with Harvey about the ICD-TEN Act’s greater implications for the healthcare industry and what happens when every penny of revenue coming through the door matters.
RevCycleIntelligence.com: Why is H.R. 2247 so important for the healthcare industry to collectively embrace?
Will Harvey: The proliferation of all of the new codes that are introduced by ICD-10 presents a significant administrative burden and additionally presents some risk to revenue cycle on the basis of the potential for increased numbers of denied claims.
The reason this legislation is so important is that it takes some of the burden for implementing this complex system off the backs of providers. Right now providers are the only people who stand to lose if something doesn’t work well with the system. We want to preserve the integrity of our practices, many of which are small businesses operating in rural or small-town areas with small numbers of providers.
RCI.com: What are your greatest concerns regarding end-to-end testing efforts with 2,500 healthcare providers from CMS?
WH: We have great concerns that doesn’t even begin to approach the number required to reassure providers that their particular set of systems that they use are going to work properly. The providers who are least likely to participate in testing are the ones who are most vulnerable – small practices – that are still in the process of getting their systems upgraded to be able to handle ICD-10 or may not be able to participate in the testing of the revenue cycle, including the sort of predictive modeling that would be ideal in this situation.
We don’t know exactly how payers are going to use the specificity in the new codes to modify their payment schemes. CMS has a relatively straightforward payment system, but private payers are likely to develop complex reimbursement changes to try and cut costs.
RCI.com: What are the primary technological limitations in relation to dual coding complications?
WH: Our electronic health record and our billing systems don’t support dual coding, meaning being able to insert an ICD-9 code and an ICD-10 code at the same time, which means that the training that we’re doing with our providers right now is in a virtual environment. We will not be able to do live environment, real patient activity around ICD-10 until after October 1st, because our systems don’t allow us to submit both and we need the ICD-9 code for ongoing operations.
Is it better to flip a switch and expect that everyone is just up to speed right away, or is it in fact more reasonable to allow that sort of on-the-job learning for this explosion in number and complexity of codes after October 1st? Of course, we obviously believe the latter.
Right now what we have is uncertainty and embedded in that uncertainty is the possibility that we see a significant period of disruption in cash flow and that certainly has short-term financial implications. What the long-term financial implications are remain to be seen and are based on the way payers use the new specificity.
RCI.com: What do you anticipate following the October 1, 2015 ICD-10 implementation deadline?
WH: I hope that the system will function as designed, but the lack of complete testing tempers my optimism. I think we will see an increase in the number of denied claims, though how much of an increase is uncertain. I also fully anticipate that after October 1st we’ll start getting notifications from insurers that certain diagnoses will be paid at a reduced level, or we’ll no longer be able to bill the highest complexity level for certain diagnoses.
People in the past, and even more recently, have talked about allowing dual coding as an option after October 1st, meaning it’s optional whether you want to submit an ICD-9 or an ICD-10 code. Most electronic systems are not going to support that, and so I don’t actually see that as a viable alternative. There are so many intermediate systems and ancillary systems, such as test ordering systems, that practically making sure they all can accept both types of codes is not realistic.
RCI.com: What are the greater implications of increased ICD-10 specificity?
WH: Subcodes are where we’ve seen the largest explosion in terms of volume related to specificity. All it does is specify the type of heart attack or the type of heart failure, or the type of diabetes, or the type of Rheumatoid Arthritis. We make the argument that in fact if a person has Rheumatoid Arthritis in the short term, the type of Rheumatoid Arthritis they have is actually irrelevant for the purposes of paying for services, paying for a doctor. If they’ve got Rheumatoid Arthritis they need to see me and I need to be paid for that. This is the primary problem of linking a diagnostic code set designed for epidemiology and public health to claims. If they indeed have to be linked, some modest protections, as we learn the system are warranted.
It’s not necessary to specify what kind of Rheumatoid Arthritis they have to know that they should be paying a bill for a rheumatologist. Rather the most direct benefit in the new specificity will be in the areas of public health, disease surveillance, and various other health system related areas and this is a long term objective. It is highly unlikely that there will be a direct benefit to any patient in the short term related to the new coding system and many have argued that the extra time taken to deal with them, if taken from patient care time, could actually cause direct harm.
I believe that the most responsible way forward is not to sacrifice short-term financial stability and patient care for a long term goal. We can accomplish both objectives by instituting the implementation periods described in H.R. 2247.
