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Welcome to this video slideshow presentation from the preparing
physicians for ICD-10 implementation National Provider Call brought to
you by the Medicare Learning Network, your source for official CMS
information for Medicare Fee For Service Providers. This educational
call was hosted by the CMS Provider Communications Group within the
Center for Medicare on Thursday October 25, 2012.
Leah Nguyen: I am Leah Nguyen, from the Provider Communications Group
here at CMS and I will serve as your moderator today. I would like to
welcome you to this National Provider Call on Preparing Physicians for
ICD-10 Implementation. HHS has announced the final rule that delays the
ICD-10 compliance date from October 1st, 2013 to October 1st, 2014. Now
is the time to prepare.
During this ICD-10 National Provider Call, Dr. Ginger Boyle, a
practicing family physician who has developed a coding educational
program for Spartanburg Regional Healthcare System in its family
practice residency program, will share her success and some practical
advice about the SRHF transition to ICD-10.
CMS subject-matter experts will also present the latest information and
updates from their areas, followed by a question-and-answer session.
Before we get started, I have a few announcements. The slide
presentation was hosted yesterday on the CMS Fee-For-Service National
Provider Call's Web page at www.cms.gov/npc. Again, that URL is
www.cms.gov/npc. At the left side of the Web page, select National
Provider Calls and Events. Then select the October 21st call from the
list.
This call is being recorded and transcribed. An audio recording and a
written transcript will be posted soon to the National Provider Calls
and Events section of the CMS Fee-For-Service National Provider Calls
Web page.
And last, please be aware that continuing education credits may be
awarded by the American Academy of Professional Coders, the American
Health Information Management Association, and the American Medical
Billing Association for participation in CMS National Provider Calls.
Please see slide 65 for more information. If you have any questions
regarding the awarding of credits for this call, please contact that
organization. We encourage you to retain your presentation materials and
confirmation e-mails.
At this time, I would like to introduce Dr. Ginger Boyle, from
Spartanburg Regional Healthcare System. She'll share some practical
pointers for providers on transitioning to ICD-10.
Ginger Boyle: Thank you very much, Leah and Holly.
Good afternoon, everybody. I am going to touch some on the preparing
physicians for ICD-10 implementation and we are going to go through some
of the slide sets that you all have as we touch on Transitioning to
ICD-10: Practical Pointers for Providers. The first couple of slides
are the CMS disclaimers. So we can go through those, and certainly, Leah
and Pat can touch on any other questions regarding those if there need
be.
So I'm going to progress through the slides that you all have,
progressing through to the disclaimers and then onto the agenda there.
We're onto slide four and I'm going to start with Transitioning to
ICD-10: Practical Points for Providers.
What we will have today is transitioning, as we look at slide five,
transitioning to ICD-10 practical pointers. Just an introduction, I work
for the Spartanburg Regional Healthcare System, here in Spartanburg,
South Carolina, and I'll do a little bit more background on our
institution in just a few moments.
We have in slide six, ICD-10: How am I supposed to get there from
here? We have multiple organizations involved in a transition from
ICD-1 all the way through to ICD-10. Most recently, in ICD-10, we have
this revision organizational structure and there are multiple people
involved in that revision steering group. And so we identify a few of
them here in slide six.
As we can see, multiple specialties have been involved in this. It
wasn't just the group of administrators; they did try to involve
physicians, leaders, and representations from each of the
multispecialties.
In slide seven, we get to the idea of the transition timeline. As we all
know, CMS has announced the delay from October 1st of 2013 to October
1st of 2014. So we're presented with that challenge am I going to be
able to get my institution, my providers, and to myself to ICD-10 on
time? The big, great answer to that is, yes. Yes, you can. And what we
need to do is use this extra time that we have to make it even a better,
smoother transition.
In slide eight, we have some examples of the ICD-10 transition
timelines. Each of our organizations and our supporting bodies have come
up with some version of a transition timeline, whether you look at the
AAPC and AHIMA or into individual professional groups the AAFP, the
American Academy of Pediatrics, the AMA. CMS, of course, has created
theirs with the basis of the ICD-10 structure and the World Health
Organization with the basis of ICD-10.
So many people have those. What do we do with them? Well, who am I and
how do I know that we're going to make it through this transition? I am
currently a practicing family physician. I do what I call womb-to-tomb
and everything in between. I am a faculty with the residency program. I
practice fill full-spectrum family medicine, including delivering
babies. I am a certified coder for both inpatient and outpatient
medicine. And in that capacity, I work to teach our residents family
medicine and coding. I also get to help our hospital system and our HIM
folks in areas of coding and documentation, as well as physician
advising. And most importantly, learn a lot from what they are doing on
a day-to-day basis.
In slide 10, I work for the Spartanburg Regional Healthcare System. So
who are we? We are a big hospital system in the upstate of South
Carolina. We have two acute hospitals and a long-term care facility. We
also have a regional hospice house, over 5,000 employees, and over 500
physicians.
In slide 11, we can see we have a large service area, a very busy ER,
quite a few inpatient and outpatient surgical procedures going in, quite
a few babies to be delivered, as well as both a chest pain and a stroke
center and an active cancer community research area.
In slide 12, our outpatient group, because we are educating both
inpatient and outpatient providers. We are part of a 16 family medicine
and internal medicine practices, OB-GYN, pediatric and multispecialty
groups, from surgery to cardiology, endocrine, rheumatology.
So slide 13, we are a large hospital organization. And when you're that
big and that good, we are recognized and tracked by a lot of these
governing bodies. We are closely watched by CMS and OIG, as many of you
all are. We are under the auspices of Medicaid, Medicare, the RACs, the
MACs, the MICs. All of these are things we need to be aware of and be
cautious for.
So what is our readiness strategy? Well, being in South Carolina, we
were one of the lucky ones, part of the initial RAC demonstration
project in 2005 to 2008. And as we all know, in 2008, we were set up
within the four regional contracts around the country. We are in Region
C. When we initially had to prepare for the RAC audit, Spartanburg
Regional set up three divisions within utilization management. We
created our HMS discharge planners that are active on the floors and
helping to get our patients smoothly transitioned out of the hospital.
We have case managers who will review all admissions for observation and
inpatient compliance. And they have become a key part of our physician
adviser group. And we have our documentation integrity team; this has
worked with our CDI, clinical documentation improvement folks. They are
the ones reviewing all of our active charts to make sure we are
documenting our comorbidities, our complications, our principal
diagnoses to make sure we're accurately capturing severity of illness
and risk of mortality.
Initially, when we were dealing with the RAC audits, we contracted with
our external physician adviser group for the observation and inpatient
backup. We eventually, over the last two years, have transitioned to a
completely in-house physician adviser group that is doing our RAC audits
and is now starting to incorporate some of the MAC and MIC reviews.
So what happens with all of this? Well, we in the last two years have
been hitting our docs with the RACs, the MACs, the MICs. And now we tell
them, you've also got to prepare for ICD-10, but we have an extra year.
So how do we incorporate the physicians and our midlevel providers into
this?
So moving to slide 17, we have what SRHS has done for its ICD-10
transition, how we prepared. We created an ICD-10 steering committee and
an ICD-10 awareness and education committee. We have a project manager
that coordinates our meetings. We have, within that, coordinated visits
with our consultants and some of the different software and hardware
folks that we use. They have come through, looked at our background,
looked at our structure, given us some project timeline outlines. We
have used our IT and our billing systems to look at our vendor
readiness, look at our different payment systems, and look through each
of the different computer aspects and applications to make sure that
they would be ready when it came time to transition to the ICD-10
applications.
For our ICD-10 awareness and education committee, our basic structure,
we realized we had different levels of education from our HIM coders,
who were going to be doing this on a daily basis, our CDI, BIT nurses,
the folks who touch the chart in any way, shape, or form patient
access, physician office staff, and, of course, the physicians.
So slide 18. Educational sessions. As we prepare for ICD-10, educational
sessions were structured from our HIM management and some of our
in-house ICD-10 trainers. We created an in-house education system,
recognizing, of course, the budgets that we all struggle with.
What we identified was four levels of educational need. Within our
ICD-10 steering committee, we realized that there were going to be
different levels based on how much of a contact these folks had with the
ICD-10 codes, with the information they needed.
So you would have one level of education for folks dealing with
admissions and scheduling; those on the floor, unit secretaries who are
actively entering orders; those who are dealing with the day to day
diagnoses and problems, such as our physicians, midlevel providers and
nurses; all the way up to the highest level, those who were coding the
chart of the information management, clinical documentation, and
documentation integrity team.
So in slide 19, we created multidisciplinary teams, including office
management and physicians that would attend the educational sessions.
The ICD-10 trainers created webinars based on PowerPoint presentations
that the office management who attended the core sessions could then
take back to their offices and give to other folks within the office.
We structured the PowerPoint presentations for physicians in brief
bullet points. We have a hospital intranet, and these webinars were
stored on the hospital's intranet to be replayed over and over.
The initial education sessions are designed to introduce ICD-10 without
being overwhelming, particularly with the delay from 2013 to 2014 and
our initiation of this preparation back in 2011, 2012, we wanted to make
providers actively aware of what was going on, but not hit them with too
much, too soon. Again, you educate somebody on ICD-10 codes in 2011
what's the likelihood that they will remember it in 2014 when you're
alternating them with RAC, MAC, MIC and meaningful use?
So the next slide number 20. Our other opportunity was to reach out to
the physicians and the midlevel providers on the side. With our CDI, and
our DIT nurses, actively on the floors with the physicians and with the
open charts, they have the opportunity to indirect directly with the
providers. They are currently gathering the information on ICD-9,
looking for the severity of illness and the risk of mortality. While
they are reaching out and trying to get some of that information, they
are able to give specific tidbits, specific insight that says, OK. This
is the current information on ICD-9. This is a little bit more of the
detail we're going to need for ICD-10.
Again, as we did with the webinars, it's small bits of information,
bullets that can be very appropriate to the physician at that particular
time. They can focus on some of the key diagnoses, some of the important
issues that we're identifying right now, such as health care-acquired
infections, the severity of illness, and the risk of mortality.
On the next slide, what they can do and what our ICD-10 education
committee does, is reach out to the people on the floors, and in the
charts, and in the offices at the time that they are actively working on
a chart.
We have what we call the paper queries or the pink slips. And these are
little notes stuck on a chart that can remind folks of some of the key
pearls that we're looking for. We've created laminated cards and flyers
that are left at the nurse's station, in the doctor's work areas, and in
any of the break rooms, the doctor's lounges, that may be a key topic or
a key learning pearl for that particular time.
We also have information and mailings that come from our chief medical
officer or some of our medical directors, that may be a current button
issue or a key issue on ICD-10 that we're trying to educate the doctors
on, such as procedures for joint injections or identifying heart
failures, acuities, chronic kidney disease stages versus acute kidney
injuries. So, again, our HIM and our CDI folks can look at what are our
key diagnoses and how can we put that in small bullets of information at
the time the physicians need it.
In the next slide, the other thing that we have utilized is the work
already done by so many others. We've touched on a lot of these
organizations having transition timeline. The great thing about these
organizations is that they have also come up with toolkits: the
professional coding organizations, each of the medical specialties
they have created resources and toolkits that, in many cases, are very
specific to the particular branch they are dealing with. So the AAPC and
AHIMA have created transition toolkits. CMS has the general equivalence
mapping, as well as the information that physicians and all hospitals
can download for ICD-9 current codes, ICD-10 current codes, in PDF
format that allows searching and transitioning to compare a 9 to a 10
code; and, of course, the World Health Organization, with its standard
of the background for transitioning all the way through to the ICD
structure.
And in the next slide. So our transition. We've talked a little bit
about how we have educated folks along the path, but how are we
identifying these key portals that we need for that education? What we
started with is, tracking the education and where it's coming from in
that source.
So similar to all hospitals, the start is where the patient enters the
system to the transition of them being admitted to the hospital. So the
key is getting the information and getting the documentation from the
beginning.
We have folks down in the ER who are educating our EMS on the new
requirements for Glasgow Coma Staging, our ED nurses and our ED
physicians to document detailed chief complaints to including past
medical history, to making sure even as we have transitioned to a new ER
documentation system, to make sure that the parts of that system are
capturing the necessary information.
And within the EMRs that you all may use in your institution, you will
find different elements and different bullets that may be, particularly,
within the ER visit that captures meaningful use elements, that captures
severity of illness, risk of mortality; and several of those bullets,
particularly, in the system we use, can even capture data that can be
used on some of the national guidelines and some different objective
rating scales, such as TIMI scores and the San Francisco Syncope score,
some of those that assist with second-order review, when you have folks
coming through trying to capture detailed comorbidities, definitions for
inpatient observation qualifiers.
So you can use that initial documentation and use your EMR to capture
key elements. The next step of education is taking what the ER system is
putting into that electronic medical record and making sure that you're
admitting and primary team is capturing that information and putting
it into their admission H&P, and their daily progress notes, and, of
course, the key that we all depend on, is that discharge summary.
Within the admitting and the primary teams, certainly one of the key
points of education for ICD-9 and ICD-10 is helping them to understand
the difference between that admitting diagnosis and those principal and
secondary diagnoses on discharge.
We have, part of our ICD-10 education, HIM and utilization management
folks working with that transition. We are looking to get both our
admitting diagnoses on the H&Ps and the daily notes to document anything
related to present on admission, document staging, document severity
and, of course, progression throughout the hospital course.
And the next slide, 24. What we can do as a hospital system is identify
your top diagnoses. Those coming out of the ER, those being admitted
from surgery, those being admitted from private offices what are the
most important diagnoses that your institution deals with and to focus
education at that point of care and at the place of service. Utilize our
in-house resources.
We have expanded some of our personnel, as we have expanded our
physician advisor in-house group. We have been able to have one of our
utilization management nurses in the ED to assist with observation and
classification observation versus inpatient classification at time of
admission. We can even start that process of having folks look at the
documentation for diagnosis specificity at time of admission.
Now the next slide, 25. So outpatient versus inpatient, we touched a lot
on what we've done for our inpatient, but how do we emphasize that same
process for our outpatient providers? Most importantly, is helping the
doctors to understand that, of course, on the outpatient side, we're
going to be dealing with the ICD-10 CM code.
Thankfully, CPT is going to stay the same. Our doctors don't have to
worry about the umpteen thousand ICD-10 PCS codes coming their way, but
they do need to understand the CM codes. We are going to progress, as
you all know, to over 70,000 ICD-10 CM codes. Doctors are going to need
to identify and describe more specifically and more complexity.
In slide 26, outpatient providers, were doing a similar process. Each
of our offices by specialty can identify their top 20 outpatient
diagnoses, their referral patterns, their diagnostic procedures. We can,
again, structure focused education at the place of service. Many of our
HIM educational sessions have gone in to individual physicians offices
to try to be convenient for them, get to a morning meeting, a lunchtime
meeting, go out and introduce these webinars, introduce these bullets,
so that they can get an overview of what we're doing with ICD-10. We
utilize the resources available in the office, who is already there that
may have attended one of the sessions or have an understanding of
ICD-10. Focused education is done based on the practice that we as
physicians have had since med school, See one, do one, teach one. So
what we can do is introduce the topic to the physician, to the midlevel
providers, let them practice those ICD-10 codes, and then hopefully,
teach one of their colleagues, teach the medical students, or teach a
resident rotating through their office. Just like the ICD-10 train the
trainer course: train a few, and have them teach each other.
Next slide. Transitioning from individual practices to the big system,
and then the big system to the individual practices. Spartanburg
Regional is a large health care system and then the regional physician
group breaks it down into smaller individual offices. The key structure
is it's a stepwise process, no matter what the size of your institution.
Make use of your available resources.
And the next slide. We're all familiar with the PDSA cycle Plan, Do,
Study, Act. This is a basic structure. You plan ahead to what you have
to do. You do it on a small basis. You tested the system. And you try it
again. You learn what works and what didn't work until youve got it
right.
So what are some of the strategies? In slide 29, we can see the planning
part. You establish the structure and the budget, and you explain to
everybody involved what is this transition, who will need to touch the
chart, who will need to be prepared for the transition. And, of course,
there are many resources that have already been outlined. Use the
resources. Create your timeline and stick to it. Even with that extra
year, this should not give us a reason to delay the project. This should
give us more time to study and repeat.
So, in slide 30, the testing and transition, we need to involve
everybody that is going to be impacted by the process to get their
thoughts on, how am I going to be impacted and, once it's tested on me,
how do I respond and how can I make it better? Monitor the impact on
your claims and your reimbursements. Have a check-and-balance system to
look for coding accuracy and productivity. Be prepared. Is this
transition going to slow down your coders or speed up your coders? Is
that going to, in turn, slow down your revenue cycle or is it going to
improve your reimbursements? Be prepared to make changes and repeat the
process.
So, in slide 31, what are some of the specific changes that are coming
our way? You all have heard about the 5010 electronic format. One of the
most important things from the physician perspective is that we're going
to increase the number of codes we're submitting. We have more space to
describe the patient. We have to understand that the physicians can now
outline more level of detail, but the physicians need to be willing to
do that, indicate the complexity of service and the need for more
services or higher level of office evaluation and management or
procedures.
In slide 32, when you've got that many more codes to submit, it allows
for that greater specificity that is now required for those meaningful
use, for the national quality indicators, with so many offices now being
NCQA-accredited or PCMH, the Patient-Centered Medical Home. These are
all things that affect CMS reimbursement either now or soon in the
future.
Some of the key pearls that we've been working on already [are] your
diabetics, your hypertensives, your heart failures. Some of the other
things we have looked at, just from a patient-care perspective, are the
complications associated with those underlying medical problems. And
some of the things that we've been able to generalize in the past in
ICD-9, we see that we can start getting more specifics.
And, as CMS has adopted some of the transition from 9 to 10, how are we
doing in our health care maintenance, in our screenings? How does that
all tie in to a Patient-Centered Medical Home? These are things that can
now be documented with the higher number of codes that we have with
ICD-10.
So, some specific examples in this transition, ICD-9 and ICD-10
comparison, the common ones that doctors need to be aware of we now
have dual diagnosis coding for diabetes, one of the most common things
that we have to code for, and accurately coding a diabetic patient, just
that one problem can have 10 to 12, easily, diagnoses on their active
problem list. In ICD-10 we have the advantage of diabetes with the
complication all being linked into one code. We don't state in ICD-10 so
much controlled, uncontrolled on their chronic problem list, but we have
the option on that particular day's note that a single code that
classifies their underlying condition and their manifestation with the
staging such as diabetes type 2 with nephropathy or diabetes type 2 with
chronic kidney disease.
And then, if their glucose is uncontrolled on that particular day, we
can add in the code for diabetes with hyperglycemia; but again, its the
option physicians need to classify and they need to clarify those
complications related to one of the most common diseases and all of this
information can be captured within our patients and our medical home
meaningful use NTQA indicators.
Some more examples as we have listed on 34, ICD-10 offers us the
opportunity to be more specific. Right now one of the things that
complicate physician documentation and coding is when you are trying to
code for a procedure, a joint injection, or some type of therapeutic, be
it a bracing, a splinting, an intramuscular injection for pain. In many
cases, in ICD-9, we have pain in limb, where I may be treating their
right leg and their left leg with two different therapies. I can't
currently clarify which limb I'm doing and it might look like I am
duplicating the treatment and trying to have a higher level of acuity or
complexity on my office visits by duplicating services on one limb.
In ICD-10 with physician education and helping them to understand the
specificity, I can make it very clear to my payer that I am providing a
service on the right side, the left side, the knee, the arm, the leg,
individual parts of the limb. So ICD-10 allows us to that extra
information.
In slide 35 as we can see, ICD-10 offers a specificity, but weve got to
get the physicians to use it. Without physician education and buy-in,
what was garbage in before is going to be garbage out now. But one of
the greatest things is that you can all be taught. We as physicians came
out of medical school with a degree, but we have a lot more to learn,
and yes, we can be taught the new system.
So slide 36, focus on the good, reassure the physicians some things are
not going to change; CPT is CPT. Some of the codes have more detail;
but, in general, if they're trying to learn the new book, the structure
is still the same, most of the chapters follow in the same pattern. Help
physicians by creating the long list and the short list of commonly used
codes. Thankfully each specialty comes out with those on an annual
basis. Utilize resources that are already available: cms.gov has
excellent resources with the general equivalence mapping, downloads for
physicians and for coders.
Utilize the resources that we've already had, look for specialty
specific codes, and educate specialists on their small area.
And then slide 37, look for the online system. Patients now have access
to all the different systems to rate us and to compare and contrast us.
Make sure that our physicians know where they're being rated and how
they're being graded. Help the physicians to see that what they're
trying to do is take care of their sickest patients, to provide the best
quality care, not just to meet national standards, but most importantly,
to do what we all went into medicine for, and that's patient care. But
if we're going to take care of our truly sickest patients, then let's
get credit for it.
And the best thing is we focus on the good. Sooner or later we all reach
the point where the light at the end of the tunnel is not just the
oncoming train but smooth, sweet success. The doctors can be educated.
And on that, we list a couple of resources for Spartanburg Regional and
some of the information for the World Health Organization.
Our next presenter is Pat Brooks from the Hospital and Ambulatory Policy
Group of the Center for Medicare, who'll be covering general ICD-10
requirements and CMS implementation planning.
Pat Brooks: Thank you, Leah.
I want to thank Dr. Boyle for providing this excellent insight on how
providers can help physicians to get ready for ICD-10. She gave some
very practical suggestions.
I'm going to add just a few important implementation issues that some of
them are repetition, but others are issues that I want you to be aware
of. Beginning with slide 41, once again, the new implementation date for
ICD-10 is October 1st, 2014. That's for both the ICD-10 CM, the
diagnoses and ICD-10 PCS, the procedures.
For those of you who want to read about the announcement about this
delay and to see the final rule, we do provide links to those in the
middle of slide 41. Weve also provided an MLN Matters article at the
bottom of slide 41, which gives you, updated ICD-10 implementation
information. This includes the new implementation date, the benefits of
ICD-10, differences between ICD-9 and ICD-10 in the code structure and
information of the general equivalent mapping that help you map between
ICD-9 and ICD-10 codes.
Moving on to slide 42, we'll state once again that ICD-10 CM, the
diagnosis part, will be used by all providers in every health care
setting. So every provider that reports diagnosis codes now will need to
learn to use ICD-10 CM diagnosis codes.
ICD-10 PCS, the procedures, will only be used for hospital claims, for
inpatient hospital procedures. ICD-10 PCS will not be used on physician
claims, even for those physician claims for inpatient services.
Slide 43 mentions what Dr. Boyle has told you previously: there'll be no
impact on HCPCS or CPT reporting. And they will continue to be used.
Moving on to slide 44, let me stress that we have a single
implementation date for October 1st, 2014 for all users for ICD-10. This
implementation date is the date of service for ambulatory physician
reporting. In other words, physicians who treat patients beginning on or
after October 1st, 2014 will report ICD-10 CM diagnosis codes for those
services.
For hospitals, the implementation date is based on the discharge date.
So for inpatient discharges occurring on or after October 1st, 2014, you
will use ICD-10 CM and ICD-10 PCS.
On slide 44, we provide information for one large conversion project
that weve done within CMS, and that's converting the inpatient
prospective payment system from ICD-9 to ICD-10. We refer to that as the
ICD-10 MS-DRG conversion project. And for those of you who want more
details about that and how we went about it, where we are in that
process, you can click on this Web page to get information.
One announcement I'd like to make is that we will be posting version 30,
which is the current version of the MS-DRG. We will be posting the
ICD-10 version of the MS-DRG within November 2012. We will also be
making available a mainframe and PC version of version 30 of the ICD-10
MS-DRG software from NTIS in early 2013.
I know a number of people who have been anxiously awaiting those and so
we're pleased to make that available.
Now, let me stress that the final version of the ICD-10 MS-DRG will be
subject to formal rulemaking. We've simply been sharing all these annual
updates to generally get input from providers on how well we are
converting the current MS-DRGs to ICD-10. And we appreciate the comments
we continue to receive on that.
Moving on to slide 46, those of you who want to know about the annual
updates to codes for ICD-10 CM and ICD-10 PCS, we post those each year
on our ICD-10 Web site. And when you get to that Web site, if you look
on the left side of the page, you'll see the current and the past year
updates for ICD-10 CM and ICD-10 PCS.
For those of you who are interested in how updates are made to ICD-9 CM
and ICD-10 codes, we do that through the ICD-9 CM coordination and
maintenance committee, and that meets twice a year. For detailed
information on that committee, weve provided a link where you can get
additional information.
On slide 47, the good news for many of you who are struggling or
worrying about moving to ICD-10. In the past, we had many updates to
codes each year, sometimes, in the hundreds, and these large code
updates were extremely disruptive.
This created problems for schools that are developing educational
material providers teaching positions physicians, those working on the
super bills that are trying to come up with the most common codes. The
good news is that we're in a partial code freeze now.
And on slide 47, we show that the last regular annual update to both
ICD-9 CM and ICD-10 was made on October 1st, 2011. For this past October
2012 and next October 2013, there will be only limited code updates to
capture only new technology and new diseases.
October 1st, 2014, the date of ICD-10 implementation, there will be only
limited code updates to the ICD-10 Code 6 to capture new technology and
new diseases.
On slide 48, we showed there will be no updates to ICD-9 CM on October
1st, 2014, as a system will no longer be a HIPAA standard. In other
words, ICD-9 CM will not be used to capture services provided on or
after October 1st, 2014.
On October 1st, 2015, one year after the implementation, regular updates
to ICD-10 will begin. For those of you who want to read more about the
partial code freeze update or you want some educational material to
share within your organization, the bottom of slide 48 puts a MLN
article that summarizes the partial code freeze.
For slides 49 to 52, we are simply providing additional reference
material for you to look at later, in case you have more questions about
ICD-10. Slide 49 is the general ICD-10 Web site, and you can see you
can sign up for e-mail updates, Twitter, latest news.
We also provide a Web site for 5010. On slide 50, we, once again,
mention the ICD-10 Web site and provide a link to calls such as the one
we're having today, that's ICD-10 teleconferences.
I would urge you, if this is your first call, to look at those prior
calls that are equally valid now to learn more details about additional
ICD-10 implementation areas. And there's a particularly good call among
these posted for ICD-10 CM basics that you'll probably find extremely
useful. We provide both the transcripts, audio recordings, and the slide
presentation.
Slide 51 gives you some links to good resources and fact sheets that
will be helpful to you. And slide 52 gives some organizations outside of
CMS that provide excellent resources through the industry, where people
can list products or services that are ICD-10-related.
Leah, that's the end of my presentation. Thank you. Leah Nguyen: Thank
you, Pat.
Our next presenter is Janet Anderson Brock from the coverage and
analysis group of the Center for Clinical Standards and Quality with an
update on National Coverage Determination and ICD-10.
Janet Anderson Brock: Good afternoon. I am Janet Anderson Brock and I'm
coming to you to discuss our progress on the translation of our edits
and related policy information that we put out in transmittal from the
past where it's concerning the national coverage process.
So, I am going to do a little context setting because I think there is
some delineation that needs to be understood right off the bat.
The first thing I would like to say is that transition is a process. And
we've been talking about transition. And translation, especially policy
translation, is just a mere activity or step within that overall
process.
So, that's what we've been focusing on. But you'll understand as I walk
through this how this relates to many other pieces, such as the
connection to the payment system, which I am sure we are all interested
in.
So, I am going to take you first to slide 54, and there are two types of
coverage that we confer here in Medicare, and they are local and
national coverage.
Local coverage determinations are determinations made by an individual
MAC or FI or carrier, for its legacy contractors, that cover a
jurisdiction. So, they are very limited in scope. These determinations,
as I said, are jurisdictionally based, with the exception of DME. For
our DME contractors, they collaborate on the policy, and the policy is
identical across the country.
If you'd like to think of it as a factor of the national coverage, you
may, because that's how we think of it. Each individual MAC will be
responsible for doing their own code translations, and that's because
there is local variation. And we have encouraged the CMBs to talk to one
another. Weve built a tool on the backend of our local coverage
determination database that allows them to see the translations that are
occurring in a counterpart jurisdiction so that they can gain the wisdom
of their CMB counterparts in other areas.
And we believe that this is going to help that transition process happen
smoothly. But it is occurring at the local contractor and not at the CMS
central office.
Now, the other type of coverage is national coverage, and that's what is
being translated out of my shop. Now, national coverage spans decades of
historical decisions. And some of them, as time has evolved, have become
more specific and more precise. Some of the ones before 1999 were
neither of those things, to be honest.
So, we've had to take a very concerted look at our history in total and
decide what our guiding principles were going to be when you talk about
translation. So, we came up with a few guiding principles.
The first and this is very big is that not all NCDs can be
translated from ICD-9 to ICD-10. Now, that might sound like a
show-stopper. But if you think about some of our older national coverage
policies, especially those that were about noncoverage, we don't do as
many of those these days. But those that were about noncoverage really
focused on the procedure, not so much the diagnosis.
So the edits that were in place in all of those things centered around
the device or the drug or the DME and not really about the diagnosis.
So, that makes it so much easier to handle especially when we are
talking about translation.
And then, the other thing, our guiding principle, probably our primary
guiding principle if you want to prioritize them, is that we in no way
want coverage to change in the midst of doing a translation.
So, in order to preserve the coverage that we have on September 30, 2014
and have the exact same coverage on October 2nd, 2014, what we've done
is go through a pretty integrated process. And I am going to explain
that in a minute.
So, what I wanted to reiterate is national coverage determinations are
national its in the title. And that our coding hasn't always been
national, but we are getting to a place now where the edits in place are
unified edits.
We put out information through our transmittals that explains what
Medicare does pay for and doesn't pay for with respect to codes. And
that information does not get modified by subsequent local policies.
There is a national policy in place. There cannot be a local policy that
comes through and modifies that in any way. Where there is no national
policy in place, a local policy can dictate the coverage for that item
or service.
While we have 330 NCDs, I'm here to tell you that approximately only 40
percent of them will be translated. I am not going to tell you the exact
number because we keep changing it every day.
But it's about 40 percent. And the reason for that, as I suggested, the
ones before 1999 had some rather indistinct language in them, or we just
say that we out and out don't cover something and it's based on the
procedure.
So, we found that order obsolete. The interesting thing about the
coverage process is, in order to retire something or take it off the
rolls, we actually have to open it up first, put it out for public
comment, and go through the entire process, which is very
resource-intensive in order to take it off the rolls. The only exception
to that is for our lab policies.
We've also determined so outside of that 40 percent that most of our
DME policies that are at the national level are not suitable for
translation. There are a few exceptions. I am not going to say 100
percent of our DME policies will not be translated. But many of them
will not.
And this is because we have DME contractors who collaborate. And so, we
have ways to make sure that coverage is unified across this nation for
our Medicare beneficiaries. That does not include going through the
rigorous process of doing shared systems edits and those types of
things.
So, we feel comfortable that, because of the extreme collaboration that
happens with our DMACs, that we've got a good alternative to shared
system edits for DME.
So, as I mentioned, we're in the process of reviewing all of our NCDs.
And we've been trying in, maybe not a 100 percent coordinated way if I
am going to get to how we're getting coordinated, this is a learning
process, to give that information out as we make these translations.
Initially, when we would write a new national coverage policy and I am
talking about in the last two years we would put out a transmittal
that would explain the coverage for ICD-9 and then we would also explain
what the translation will look like for ICD-10.
Now, we didn't put an effective date on that ICD-10 translation. But it
is there in the transmittal. And those transmittals are easy to find if
they are topic-specific, because they start with the title ICD-10. And
it will say ICD-10 or ICD-10 screening for alcohol misuse. And so, they
are easy to identify if you are looking for them. If you're not looking
for them, you wouldn't know they're there.
So, we've taken a second approach because, of course, not everything is
new. We have a history, as I mentioned. So, how do we translate those
historical documents, those NCD policies that still live and breathe and
are important for payment?
We've looked at them. We found our 40 percent that we feel are suitable
for translation and we've been doing what I like to consider omnibus
transmittal. So, it's a release we call them change requests. But you
are familiar with them as a transmittal.
We do a release that gives you a translation for many NCDs. And those
NCDs don't necessarily have to relate to one another in any way. They
are just the ones that, for that release, were ready to go through and
be displayed to the public. The way that we got through the translation
process is this, because I think it's important for you to understand
the steps that we've taken.
We have enlisted the help of others, starting with some subcontractors
that have been very important to us. One of them was 3M and the other
was WPS. WPS is a MAC. And what they bring to the table is their coding
experience and their local flavor as they process our claims. So, that's
extraordinary helpful.
3M, of course, the creator of the CPT tool and knows an awful lot about
the ICD-10. So, they bring a lot to the table as well.
So, what we've done is we have taken our ICD-9 policy we've taken the
policy as it translates in ICD-9, double-checked it to make sure that
there were no changes from the time that we originally picked those
ICD-9 codes, made it appropriate, and then looked at the CPT translation
to see what the ICD-10 translation would look like. But we didn't stop
there, because there is a lot of medical subtext to some of these
translations, and it's so important to make sure that we're getting an
equivalent translation that will still create the same payment at the
end of the day.
So, once we had that process, we took it and we handed it off to our
medical officers and also to a consensus body, which consisted of a
medical director in each of the MAC jurisdictions, who was very nice and
volunteered their time to go through this, because they found the
importance of this to warrant that kind of investment.
So, they went through and they said, Yes. You know what? We agree with
the translation, or We think you missed a code here or we think this
code is inappropriate.
We wanted that process to happen so that we can make sure that we didn't
put anything in our shared systems, as far as an edit that would
preclude payment that wasn't there before. We always know that things
can be tightened up in a jurisdiction and that individual local
coverage, if there was contractor discretion, would take care of some of
things that you are used to seeing in your jurisdiction. But we didn't
want to do that across the United States, because that wasn't our
mission here.
After we did the consensus building with our medical director, we then
did a validation check to make sure that we were comfortable with any
changes that were made. And only then did we release it to our systems
maintainer. So, here we're talking about a fourth level of review who
said, You know what? This isn't going to break the system, or This is
exactly what we had in the system before in the sense of as the claim
come through, it's going to pay the same way or they told us when it
wouldn't. And we made sure that we worked through those.
At the same time, we also looked at things like frequency to make sure
that everything was true to the stated national policy that's in our NCD
manual and what's in our claims processing manual. So, this was a very
long step, but an important step for us.
And only then were we ready to show it to the public. So, that's how we
got through the entire CR process. And I am pleased to say that we've
already released our first omnibus CR, change request, and that the MLN
Matters article that is referred to on slide 56 points you to that
transmittal.
You can get there and what you'll see might be a little daunting, so I
am going to tell you that right off the bat.. But you get an idea of the
requirements that we put in place. And those are pretty basic. It's
replace these ICD-9 codes with this ICD-10 codes. That's easy.
Then, you get for this one actually 36 spreadsheets of codes. And
what we tried to do to make it as user friendly as possible is, we've
labeled each one of those spreadsheets as a separate file. So, you get
them as sort of an attachment.
Those separate files are titled by the NCD number. So if it were
artificial hearts, I think that's 20.6. I might have that number wrong,
but we named it by the title of the NCD and the NCD number. And you
opened it up, and you get one file for Part A, and you get one file for
Part B.
So we hope you can go right to where you want to go to find the
information that you need, and you'll see the translation. We show what
it was for ICD-9; we show you what the translation is for ICD-10.
At the same time, we also have information in there about the frequency
edits; so you can see that it is unchanged and any of the messaging that
was important for our contractors especially but may be instructive to
others. Providers may care about thisthe messaging as well.
We are going to do two more of these omnibus CRsthese omnibus
transmittals. You'll see one very soon in April. We will have an MLN
Matters article when that one comes out. The transmittal number to look
for is 8109.
And then we will have our final translation CR transmittal in July of
this year. At that point, all new translations will occur through
individual topic-specific transmittals, as I suggested we were doing
previously. We will continue to do that; we don't want a backlog of
stuff that we need to translate. And we will take a second look at the
translations that we've made right prior to ICD-10 going live to make
sure if any new codes creep in during that partial freeze [and] that
we've updated the translations that we've made to make sure that
everything is ready come October 1st, 2014.
And with that, I am going to turn it back over to Leah.
Leah Nguyen: Thank you, Janet. Our final presenter is Chris Stahlecker
from the Administrative Simplification Group of the Office of eHealth
Standards and Services with an update of ICD-10 and administrative
simplification.
Chris Stahlecker: Thank you, Leah. I am really pleased to be here today,
and I just wanted to draw a little bit of a differentiation between some
of the prior presentations and this presentation because I am speaking
from the, as we have indicated, Office of eHealth Standards and
Services. That is the area that actually develops the regulations.
And so we did need to publish this date after it was decided in April of
this year to make a modification, and I wanted to cover a little bit of
the rationale of why the date changed. So, I'll slide right over to
slide number 58 in our presentation.
It was September 5th that we published the final rule, and you've heard
many times today it's been changed to October 1st of 2014.
I wanted to go over some of the rationale why that date was selected and
why it changed at all.
For industry watchers, the signs were there, although not from any one
group or single issue that led to a decision to delay or change the
date, but rather, there was a series of events and issues that occurred
that the industry clearly was signaling that they needed more time. One
of the first signs was our version 5010 implementation.
I have to note that if you're not on version 5010, there's no way that
you're going to be able to implement ICD-10. 5010 was the precursor
project. And while its just changing a format for the electronic
transactionit was considered a pretty easy transition, much easier than
ICD-10there are lessons learned or lessons to be learned from that
implementation.
First, there were some errata with the transaction standards, even
though that the corrections may have been simple and not affected
everyonesome typographical errors or certain data content. Those
changes did affect the vendor readiness, and that was like a domino
effect. The vendors were delayed in delivering their products. They were
backlogged there, and then the installations were backlogged. Billers
that needed those new versions of software were prevented from extensive
testing.
Additional difficulties occurred when some payers front-ended systems
and edits. There was some linkage with submitters and providers that did
not or was not recognized until the transition to production. It did
not. It was a problem that perhaps didnt exist in the testing
environment because, if there were some changes, they were only
recognized once a move to production occurred.
So with the system, even though these are all standards, they're all
subject to interpretation, and that adds another layer of complexity.
Overall, CMS listens to industry feedback regarding some of the reasons
for looking for a delay. Providers were experiencing potential or true
delays in payments or nonpayments.
We considered that situation looking forward and realize the potential
for providers not meeting payroll or shutting down operations and then
the trickle-down negative effects on patients access to care. And that
was essentially the primary reasons for considering a delay in the
ICD-10 implementation.
Providers werent the only ones, though. Once we did an extensive
outreach, other industry segments offered some of their concerns. They
admitted that after the delay was announced, there's a consideration of
the delay, that their members could truly benefit from some additional
time.
So then the question became how long? And we dont want you to think
that we just picked a year delay. We heard a lot of comments from
industries. Some were saying dont move it from October 1st, 2013; some
were saying go out to 2015. Some were looking for ICD-11. Essentially,
when we balanced the books, and we looked at all of the comments, we
believed that the 1-year delay timeframe balanced the overall needs.
That additional year will give the small provider practices and other
entities some additional time and doesnt significantly penalize those
entities that have already invested heavily with considerable time and
effort based on their initial understanding of the October 2013 date.
And well move to slide 59. One of the key comments, howeverand Ill
point back to the NCDHS hearings in June of this yearwas that a trend
was in the comments. It said, Please do not have an extensive
implementation coincidental with ICD-10.
So on our slide 59, were showing you what administrative simplification
regulatory dates, compliance dates are coming up on the horizon. We got
January 1st, 2013, with our eligibility claim status operating rules.
Followed closely, December 31st, the same year, health plans must
certify that they are compliant with eligibility claim status and EFT
and ERA standards associated with the operating rules.
Then you'll see that the next date on our chart here points to January
1st, 2014, and you're going to be saying, Why are these dates seemingly
flip-flopped? How can you say that you're attesting to being compliant
with the standard before its actually effective?
And I wanted to point out, right at the get-go here, that this
discrepancy will be addressed shortly. But just see right in the center
of this slide that ICD-10 does stand aloneOctober 1st, 2014. Well
follow it up with the November 5th, 2014, where health plans, the large
ones, must have obtained their health plan identifier, and note that
small plans have an additional year. Its just getting yourselvesthe
health plansgetting themselves enumerated.
Then on December 31st, 2015, our additional operating rules; hopefully,
then January 1st, 2016, will be attesting to being compliant. The final
date that we have here is November 7th, 2016, where the health plan
identifier will actually begin to be used in the transactions. Not begin
to be used, let me correct myself.
All of the transactions must be using health plan identifiers, and only
the health plan identifier, where that piece of data is being
communicated. So theres a whole suite of activities that I'm going to
talk about toward the end of this presentation about how were going to
support all of these things by emphasizing that the October 1st, 2014,
date is not expected to be changed again.
Moving on to slide number 60. How does ICD-10 integrate with the overall
EDI? Well, the connection among CMS is eHealth Initiatives. Its
unmistakable. Interoperability, and thats one of the end games here.
Interoperability requires the use of uniform health information standard
such as ICD-10, along with SNOMED.
They work together as structured documentation to demonstrate meaningful
use and make sure that the administrative transactions reflect the
appropriate clinical event. So you have SNOMED the clinical standard and
ICD-10 as the administrative transaction. They need to align to make
sure that the information thats being conveyed is actually the
appropriate information.
So how is interoperability, including the monitoring and enforcing of
Electronic Health Information Exchange Standards, an essential component
of the National Health Information structure? Interoperability at the
national level benefits clinicians with having a longitudinal medical
record with full information about each patient.
Consumers also have improved access to management and management
capability for their own health status through their personal health
records and access strategies, such as mobile health applications via
smartphones and touchscreen tablets. Consumers can also move more easily
across the health care settings without concern that their information
has been lost. Payers can benefit from the economic efficiencies, fewer
errors, and reduced duplication in the reimbursement process.
The interoperability is the foundation for public health reporting,
bioterrorism surveillance, quality monitoring, advances in clinical
trials, and health care policy decisions. The rest of the globe is
already on ICD-10. The United States is catching up.
When it comes to ICD-10 for that matter, all of the HIPAA standards,
medical code sets, identifiers, and operating ruleswe first need to
consider how they integrate and contribute to this health care endgame,
including their contributions for health care quality.
The first recognition of this integration was the inclusion of ICD-10 in
the EHR certification criteria and the recent Meaningful Use Stage 2
Regulations. And going forward, you will hear more aboutmore
conversations about this intersection of data, quality, standards, and
the other eHealth Initiatives.
Moving to slide 61, so what has CMS been doing with their implementation
of ICD-10? And Ill just point out that the Office of eHealth Standards
and Services has oversight responsibility here within CMS for
implementing ICD-10. And since the delay was initially signaled in
April, CMS has continued with its ICD-10 implementation. We continued to
push ahead with internal implementation efforts, but of course, like
everybody else, some of our work has been slowed down waiting for the
compliance date to be announced.
Our ICD-10 Steering Committee continues to meet every other week and
hash out some of the dependencies and the timetables in progress towards
the October 1st, 2014, implementation. We estimate overall that were
approximately 50 percent complete. Thats not to say that 50 percent is
all of the work. There are some areas that are totally completed, while
other areas have to wait for preceding dependencies to be completed
before they can be fully closed out.
Our industry outreach is going to be stepped up to concentrate on some
practical tools aimed at reaching small providers and hospitals. And our
goal is to have preparations for as many of our systems and business
processes as possible completed by October of 2013 so that we can devote
the remaining year to testing.
And thats to segue to another important area, slide 62our ICD-10
testing and compliance. One of the other very valuable lessons learned
from version 5010 is that, despite all of our standards, operating rules
identifiers, when it comes down to our own industry, we are still
lacking a common understanding of what we are articulating.
What do we mean with end-to-end testing? What do we mean with
compliance? What do we mean with readiness?
When the survey with the industry waswhen the industry was surveyed as
to their readiness for version ICD-10, the responses were typically very
positive and that only served later on to learn that we are all working
off of our own individual interpretations and concepts of what we meant
by readiness. That same applies to end-to-end testing and compliance:
what do these terms actually mean?
More importantly, how does our industry gain enough confidence to say
that we are ready for the ICD-10 cutover date? They are very crucial
conversations and questions that will have to occur; that will determine
how we operationalize ICD-10 as well as the other HIPAA standards. Based
on this 5010 experience, we cannot assume agreement or understanding of
the answers.
Each question begs some discussion and consensus across CMS and across
all industry segments. We know that there are many industry groups
already working on the testing question, and we intend to have an active
role on those efforts. Were willing to tee up these discussions and
believe potential consideration given to the national committee on vital
and health statistics and the FACA Committee thats responsible there
for making recommendations to the Secretary could be an appropriate
venue to make this happen.
And were also proactively working on a pilot to develop a protocol so
that standards that the Secretary is considering for adoption are
pretested before they are recommended for implementation across the
industry. We also have another pilot that I'm going to speak about to
explore end-to-end testing, questions, and implications. So let me move
on to slide number 63.
What is our roadmap to interoperability? Again, referring back to the
recommendations heard at the NCDHS hearings in June of this year, the
industry was clearly requesting CMS to provide guidance. One specific
request is for a roadmap that is understandable and reflects prioritized
deliverables.
The roadmap needs to clearly indicate the activities per milestone and
the timeline. Well be taking some of the content, the regulations
identified in that "what's coming" slide in my presentation earlier, and
recommending an appropriate set of activities based on industry
collaboration.
This isnt CMS just defining them. We have a contractor under way now to
help us with an end-to-end definition of pilot testing, and these
activities will be presented, along with the timelines that complement
those activities, with results from our end-to-end pilot test. It will
also include our HIPAA next, or our 6020 pilot that I referred to you on
our prior slide, and we expect to have a very cohesive and comprehensive
communication program addressing the FY 2013 activities. So I can say
more to come, and we hope to be speaking with you soon about some of
those deliverables.
Operator: And your first question comes from the line of Samuel Raj.
Samuel Raj: Hi. This is Samuel from Glenwood. I have a question about
the ICD-10 and SNOMED for the electronic medical records we are using.
Because so far, for the problem lists we are maintaining with our ICD-9
codes, and now when we migrate to ICD-10 for meaningful use, they call
for SNOMED codes. So there is no one-to-one mapping between those tools.
So how do Ihow am I going to maintain two sets of codes for every plan?
Our problem is entering time going to have.
Chris Stahlecker: All right. Its Chris Stahlecker here. Thats really a
question that should be answered by our electronic and health initiative
team. We can take that question back. I do believe you're going to need
to make your best attempt at looking at those SNOMED codes, and the
software certification criteria for presenters that are preparing those
systems have now included the capability of ICD-10.
So ICD-10 is an option, but you doyou must implement SNOMED codes. So
that will take significant maybe not significantbut it will take some
doing on your part. We can take this question back though and try to get
you more wholesome answers. There may be some best practices about how
to go about that so we can take that in.
Samuel Raj: Thank you.
Chris Stahlecker: I think you have an e-mail address. Leah is going to
give you now.
Leah Nguyen: Yes. We have an e-mail address listed on slide 26 66. Its
icd10-national-calls@cms.hhs.gov. Thank you.
Samuel Raj: Thanks.
Operator: Your next question comes from the line of Donna Shaw.
Donna Shaw: Hello. Has there been any information that maybe CMS has
received from payers that may not be converting to ICD-10? And I'm
probably specifically referring to workman's comp in some States.
Chris Stahlecker: This is Chris Stahlecker. I don't believe that we've
received that feedback at this point. We haven't issued a survey in some
time, and we do want to issue a survey. And so we do note some have
like, you know, are expressing concerns, but we do believe that the
improved communication education and outreach program that we will be
putting forward will give the industry some general assistance in
tooling up their delivery schedules, so but your point, being
point-blank, well, the OK, but I've forgotten the term you said for
the claim types you're talking about.
Donna Shaw: Like the workman's comp I was referring to.
Chris Stahlecker: We haven't heard of that in particular, but we can
look into that, and if you want to send in an e-mail to the address that
Leah just mentioned, we can get to a direct response. Donna Shaw: Great.
I appreciate that.
Leah, can you provide that e-mail again, or will it be posted?
Leah Nguyen: Oh, sure, it's actually on slide 66. It's ICD-10
Donna Shaw: OK, great.
Leah Nguyen: OK.
Donna Shaw: Yes, great. Thanks.
Chris Stahlecker: And of course, these questions will give us some
interesting opportunities to post frequently asked questions. So we're
anxious to take the next one.
Operator: Your next question comes from the line of Ular Williams.
Ular Williams: Yes, will there be a presentation for DME providers in
transition of the ICD-10?
Pat Brooks: This is Pat Brooks. So we haven't decided on what our next
presentation would be. I don't know that we have focused particularly on
DME providers. We try to keep these pretty generic on all kind of
providersthe ICD-10 issues. But thank you for making that
recommendation.
Ular Williams: Thank you.
Pat Brooks: Thank you.
Operator: Your next question comes from the line of Kevin Baron.
Kevin Baron: Hi. I had a question regarding we're a very small
hospital here in Chicago, and I was just wondering what your
recommendation was as far as implementing a CDI program along with the
ICD-10 implementation. Currently, we don't have a CDI program, and I
know it's something that our hospital has been talking about. But you
know, in meeting with other vendors, they you know, I just want to
know what other hospitals are doing.
Leah Nguyen: Why don't we have Dr. Boyle give her feedback from an
actual person working in a hospitalwhat she thinks about that? Kevin
Baron: OK.
Ginger Boyle: Now, again, is this how your particular institution can
connect your CDI program to ICD-10? Is that what you are referring to?
Kevin Baron: Well, yes, pretty much. I want to know what the standard in
industry is, because we don't have a CDI program here at our hospital.
And some of the vendors with the ICD-10 implementation want to do both
at the same time, and we're a little apprehensive about rolling both
programs out at once. So maybe if you guys have any suggestions or what,
you know, other standard industry people are doing as far as about
having the CDI programis it better to roll both of them into one or to
do the implementation of ICD-10 and then wait on the CDI?
Ginger Boyle: Do you have a structure in your institution at this point
that helps to capture information, like from the inpatient documentation
or the active open chart? What are you doing right now to try to tease
out information for severity of illness and risk of mortality?
Kevin Baron: You know, we have our director of HIM, and their department
currently does that now but not at the level of a CDI program.
Ginger Boyle: OK. So are they doing it on closed charts, or do the HIM
folks ?
Kevin Baron: Closed charts, yes.
Ginger Boyle: OK. So I would say that probably one of the easiest
one of the simplest stepwisestarts is, I would, while you're still
working on ICD-9, is try to see what you have within your institution,
and if you have the available resources, to have somebody start the CDI,
because I think you can start the CDI and have people looking at the
active charts on 9 and get that up and rolling now.
With, again, some of the resources that CMS, AHIMA, and the CDI
governing agencies or collective groups have to helpcritically, nurses
or documentation specialists within HIM. There are resources within the
CDI networks to help those people transition from 9 to 10. And so I
would propose that the short and simplerunning them parallelwhether
you utilize an outside vendor to run them parallel, or I would look
within your own institution and see who in your HIM department may be
interested in moving from that closed chart investigation to an open
chart investigation and see if you may have within your institution
people who would like to venture into the CDI world. Kevin Baron: Right.
OK.
Ginger Boyle: But you may not need the vendor to incorporate both ICD-10
and CDI in your institution at the same time if, within your network,
you may have a CDI resource already built in.
Kevin Baron: OK, thank you very much.
Ginger Boyle: Yes.
Operator: Your next question comes from the line of Faith McNicholas.
Faith McNicholas: Hi. This is Faith McNicholas from the American Academy
of Dermatology. I wanted to ask CMS staff about whether there has been
any consideration from transitioning from ICD-9 directly to ICD-11 and
whatif there's any discussion going on. Thank you.
Chris Stahlecker: Hi. It's Chris Stahlecker. Yes, we did have a look at
that, quite frankly. But the ICD-10I'm sorry, the ICD-11codes are not
available yet. And if we look at how long it took for the ICD-10 codes
to be developed, we could not even envision ICD-11 codes available for
several years. And quite frankly, you know, we just can't continue to
exist on the ICD-9 codes, that we cannot advance our health care
delivery system based off of code values that are becoming obsolete and
very complicated to convey any meaningful information. It's causing a
lot of additional documentation to be required, and so we just can't
stay on the 9 codes. So we don't really have an option here.
Faith McNicholas: Thank you.
Operator: Your next question comes from the line of Trina Ewing.
Trina Ewing: Trina Ewing, with Memphis Gastroenterology Group. We're a
GI practice, and I noticed on slide 32 you mentioned 12 codes for
specificity for meaningful use. I was wondering if you could just
elaborate more on that slide 32?
Ginger Boyle: What I'm implying on that is the number of diagnoses that
physicians can include when they are coding an individual office visit.
Right now, on the 1500 form, you're limited to those four diagnoses. And
as we expand, some of the other documentation and claim submission
forms, be it 5010 or whatever comes down in the futurethat physicians
will be able to or claims will be able to include more than just four
codes, and physicians will be able to better elaborate and better
utilize the multiple codes in ICD-10 to describe how fixed their patient
is.
Trina Ewing: OK. So with regard to the health care maintenance
screenings, for example, the colonoscopy, are you just saying that we
will be able to provide more specific diagnosis codes, like the
screening as well as any health risk factors?
Ginger Boyle: Yes.
Trina Ewing: OK.
Janet Anderson Brock: This is Janet in the coverage and analysis group.
I think it's important for the screenings, especially for all of those
of you who do provide preventive services, to remember that, for
screening, we don't really base it on diagnoses. Those, you know, that
that's really the diagnostic services that we provided that are related.
For example, we have a screening mammo; we have a diagnostic mammo.
For screening, by and large, those are procedure-based. Soand frequency
edits are employed, depending on the technology, but it's not usually
diagnosis-based unless we're talking about a high-risk/low-risk split,
and that's usually right out of statute.
Trina Ewing: OK. OK. That makes sense. That's what was confusing,
because I know currently we'd submit G codes for the screening
colonoscopy, so I didn't really understand how the 12 new diagnosis
codes would affect those procedures.
Leah Nguyen: Thank you.
And, Holly, how many participants do we currently have in the queue?
Operator: Apparently, we have 11 participants in queue.
Leah Nguyen: OK, it looks like we have time for one final question.
Operator: Your final question comes from the line of Rachel Cotler.
Rachel Cotler: Hi. I work for Liberator Medical Supply. We supply
durable medical equipment. My question is, will the DME providers have
to obtain a new prescription so the patients are receiving supplies on
or after October 1st, 2014? Right now, our prescriptions have the ICD-9
code on them when we bill for the services that we provide. Are we going
to have to replace the thousands of prescriptions we have on file?
Pat Brooks: This is Pat Brooks. I don't totally understand your
question, because I don't work in that area. All I can tell you is that
if you report ICD-9 CM diagnoses codes now, you will have to replace
that those with ICD-10 CM diagnosis codes beginning with services on or
after October 1st, 2014if that addresses your question.
Rachel Cotler: OK. So can I just ask one more thing in regard to your
answer? You know, to be proactiveI mean, we have literally thousands of
patients that we service. And if we try to get prescriptions earlyyou
know, a couple of months in advance to try to keep up with it to make
sure there's no lapse in supplies for our patients that are using
catheters and, you know, different durable medical equipmentare we
going to be able to bill with the new codes before October 1st?
Pat Brooks: The answer is, once again, it's a hard-and-fast rule that
you cannot report ICD-10 codes for services provided before October 1st,
2014.
Rachel Cotler: I see.
Pat Brooks: And you must pre-plot, supply the 10 codes for services
provided on or after October 1st, 2014.
Rachel Cotler: OK, thank you very much.
Pat Brooks: Thank you.
Leah Nguyen: Unfortunately, that's all the time we have for questions,
and we apologize that we did not have more time for questions today. If
we did not get to your question, you can e-mail it to
icd-10-national-calls@cms.hhs.gov. The address is also listed on slide
66. Before we end the call, for the benefit of those who may have joined
the call late, please note that continuing education credits may be
awarded by the American Academy of Professional Coders, the American
Health Information Management Association, and the American Medical
Billing Association for participation in CMS National Provider Calls.
Please see slide 65 for more details.
I would like to thank everyone for participating in the Preparing
Physicians for ICD-10 Implementation National Provider Call.
An audio recording and written transcript of today's call will be posted
soon to the CMS Fee-For-Service National Provider Calls Web page. Again,
my name is Leah Nguyen, and it has been my pleasure serving as your
moderator today. I would also like to thank our presenters, Dr. Ginger
Boyle, Pat Brooks, Janet Anderson Brock, and Chris Stahlecker.
Have a great day, everyone.