New House Bill Requires ICD-10 Transition Period Testing
By - The House of Representatives has introduced a new bill, H.R. 2247, requesting a mandatory ICD-10 transition period following the October 1, 2015 ICD-10 implementation date. This bill – the Increasing Clarity for Doctors by Transitioning Effectively Now Act (ICD-TEN Act) – commands the Secretary of the Department of Health and Human Services (HHS), Sylvia M. Burwell, “to provide for transparent testing to assess the transition under the Medicare fee-for-service claims processing system from the ICD-9 to the ICD-10 standard, and for other purposes.”
“During the ICD-10 transition period, it is essential for CMS to ensure a fully functioning payment system and institute safeguards that prevent physicians and hospitals from being unfairly penalized due to coding errors,” states Diane Black, RN (R-TN-6), in a letter to legislators. “Reimbursement could be significantly delayed due to simple mistakes in classifying one of ICD-10’s thousands of sub-codes. The effects of the change could be overwhelming, particularly for smaller provider offices with fewer resources,” she explains.
This bill requires HHS to administer “comprehensive, end-to-end testing” accessible to each healthcare provider. The purpose of conducting the testing is to ensure the Medicare fee-for-service claims processing system operates efficiently with the new ICD-10 code set. Under the bill, if benchmarks are not met or exceeded, HHS will be required to tangibly define needed steps to ensure seamless ICD-10 functionality.
ICD-TEN also advocates for the implementation of an 18-month “safe harbor” transitional period to safeguard healthcare providers who submit erroneous sub-codes. The result will likely be a decrease in claim rejection and payment denial due to sub-coding specificity.
This bill will not create further ICD-10-CM/PCS implementation terminations or delays. Nor will the bill necessitate CMS accept dual coding. During the period of transition and extensions, reimbursement claims submitted to CMS cannot be denied if they contain vague or incorrect sub-code, according to the bill.
Mitigating negative effect, burden, and financial risk for healthcare providers is the ultimate objective to ensure seamless revenue cycle management.
