Healthcare Revenue Cycle Management, ICD-10, Claims Reimbursement, Medicare, Medicaid

Policy & Regulation News

100 Day ICD-10 Countdown: CMS’s Top 5 Steps for Readiness

By Jacqueline DiChiara

- The official 100 day countdown until the October 1 ICD-10 implementation deadline recently came and went. To foster industry-wide knowledge and preparation, the Centers for Medicare & Medicaid Services (CMS) introduces a series of the following 5 steps from its Quick Start Guide.

ICD-10 implementation

Formulate a plan, decide clearinghouse roles

According to CMS, getting access to ICD-10 codes is key. They are indeed readily available, CMS confirms. Consider a plethora of available formats, such as code books, practice management systems, electronic health record (EHR) products, and a variety of smartphone apps.

CMS additionally advises to consider what roles your clearinghouse or clearinghouses play within the upcoming October transition. Clearinghouses provide assistance by identifying causes of claim rejection and figuring out how to fix rejected claims.

It is imperative to consider what specific processes and systems require ICD-10 updating. Consider billing, coding, reporting and analysis, clinical documentation, health records, and order entry as possible updating focuses.

Develop a well-trained staff, identify top codes

According to CMS, training your staff to get them up to snuff should be a top priority to ensure ICD-10 preparation. CMS lists a variety of resources to help advance staff training:

Free resources that may prove useful are also available from medical societies, healthcare professional associations, hospitals, health systems, health plans, and vendors.

Identifying top codes should be a main priority, says CMS. Consider what ICD-9 diagnostic codes your practice comes across the most frequently as a baseline for future coding initiatives, CMS says. Perhaps targeting the top 25 or so codes is a viable approach, CMS suggests.

Update your processes, get your forms ready to go

It is crucial to update both hard-copy and electronic forms, says CMS. Make sure important new coding concepts are captured via clinical documentation, such as laterality, initial or subsequent encounter for injuries, specific pregnancy trimesters, and fracture types. CMS also advises to resolve those documentation gaps identified while coding top diagnosis in ICD-10.

CMS recommends reviewing NCDs and LCDs with ICD-10 codes to help ensure consistency with internal policies, such as documentation processes and billing. ICD-10 does not affect the use of CPT and HCPCS coding for outpatient and office procedures, CMS confirms, additionally stating both outpatient and office procedure codes will not change come October.

Confirm systems are ready via vendors, health plans

CMS recommends making a call to vendors, third-party billing systems, and clearinghouses to help avoid potential reimbursement hiccups and workflow hindrances. Ask them for testing opportunities, CMS says. Transition costs for smaller medical practices could be much lower than was projected, as many EHR vendors are including ICD-10 within the systems or upgrades at either nominal or no costs to customers, CMS maintains, additionally confirming minimal costs to providers for ICD-10 software and systems costs.

Test your systems and processes

Lastly, CMS recommends you can use your ICD-10-ready systems to generate claims, code a patient encounter, schedule office visits and outpatient procedures, and perform eligibility and benefits verification.

If you anticipate your systems not being up to par come October, consider additional options to submit claims to health plans, CMS says. MAC websites offer free billing software for Medicare providers. And, Part B claims submission by online provider portals in approximately half of MAC jurisdictions is possible, CMS confirms. Also consider paper claims for those healthcare providers meeting Administrative Simplification Compliance Act waiver requirements.


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