Top 5 Facts and Misconceptions about the ICD-TEN Act
By - The bipartisan ICD-TEN Act is perhaps sparking confusion among the healthcare industry. As part of a recent series of ICD-10-based bill proposals, including a two-year “grace period” without denials to avert unfair penalizations to physicians due to coding errors, clarifying fact versus fiction regarding the ICD-TEN Act is key to advance accurate knowledge across various spectrums of the healthcare industry.
The American College of Rheumatology (ACR), a physician group that has previously confirmed tangible support for the ICD-Ten Act, outlines several myths about the ICD-TEN Act and differentiates stabilized truths from merely erroneous beliefs.
The overall importance of the ICD-TEN Act, stated Will Harvey, MD, MSc, FACR, Government Affairs Committee Chair of the ACR and practicing rheumatologist at Tufts Medical Center, in a recent RevCycleIntelligence.com interview, is that it alleviates some of the burden healthcare providers face while implementing a rather complex system.
“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,” Harvey states.
A highlight of the ACR’s top debunked ICD-Ten Act myths are as follows:
Will there will be reimbursement blocks?
Contrary to popular belief, the ACR says the ICD-TEN Act clearly distinguishes between diagnosis code errors and sub-code errors. The ICD-Ten Act’s “safe harbor” proposal will not weaken the determination of coverage, medical necessity, and care quality, says the ACR.
“The language in Rep. Black’s ICD-TEN Act strikes the appropriate balance between significant or intentional errors in diagnosis codes, and minor errors due to sub-coding technicalities,” confirms the ACR “H.R. 2247 would allow payment if a provider used an unspecified or inaccurate sub-code, but the actual ICD-10 diagnosis code used by providers would still need to be correct in order to receive reimbursement,” the physician group adds.
Subcodes are not relevant to the determination of coverage or medical necessity, says the ACR. “Relying on the most relevant part of the ICD-10 codes will allow for coverage determinations and medical necessity during the implementation period,” the ACR claims.
Will inaccurate codes impact payment?
The myth that safe harbor simply ignores Medicare’s fiduciary obligation to ensure proper payment is simply untrue, says the ACR.
“Determination of medical coverage and medical necessity has to do with using the correct ICD-10 diagnosis codes, not the sub-codes that are the focus of the ICD-TEN Act safe harbor provision,” the ACR confirms. ICD-10 codes are not allowed to be unspecified or inaccurate for payment purposes under the ICD-TEN Act, the physician group states.
“Implementing the new code set without this safe harbor period ignores Medicare’s ethical responsibility to preserve access to physicians and medical services for beneficiaries,” the ACR maintains. “The fact is that no patient’s disease will change from September 30 to October 1, but there will be new barriers to describing that illness and new opportunities for Medicare to deny services based on these technicalities.”
Will risk of payment occur?
Says the ACR, “The long-term goal of supporting public health and epidemiology should not come at the risk of payment instability, patient access, or doctor-patient time – three very real and imminent threats to quality care on October 1 if a safe harbor period is not instituted.” The ICD-TEN Act responsibly addresses ICD-10 implementation anxieties, says the ACR, which confirms an 18-month window is indeed a considerable amount of time to allow practices to amply adjust to new coding procedures.
What about fraud and abuse?
Another notion worth clarifying for the healthcare industry is that the ICD-Ten Act permits errors only within the sub-code, not the main code.
“The ICD-TEN Act was carefully worded to allow payers to detect and differentiate these important differences in diagnoses contained in the main code (S12 vs. S62), while providing time for providers to learn the nuances of the hundreds of sub-code possibilities,” maintains the ACR.
Safe harbor means incomplete documentation, system disruption?
“The ICD-TEN Act’s safe harbor provision ensures that coding specificity is achieved without disrupting patient care,” says the ACR. “Not allowing this safe harbor period would lead to widespread payment rejections and exacerbation of existing patient access issues,” the physician group adds.
Regarding concerns regarding widespread system disruptions, the ACR says healthcare providers already face a heavy abundance of ICD-10-based uncertainties. Payment instability is a primary concern, as is the possibility of rejected claims due to minor sub-code errors.
“We believe it is in the best interest of all payers to implement the safe harbor period,” maintains the ACR.
