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Page 1 April 24, 2014 Prepared for Tennessee MGMA Final Countdown to ICD- 10… Tennessee Medical Group Managers Association April 24, 2014

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ICD-10 implementation was closer than ever until a March 31 Senate vote shook up the healthcare industry and left everyone asking this question. As new guidance develops, readiness for ICD-10 implementation remains a focus for healthcare administrators, IT vendors, providers, billers, and coders. At the 2014 TMGMA Spring Conference, PYA Consulting Managers Linda ClenDening and Valerie Rock presented “Final Countdown to ICD-10.”

TRANSCRIPT

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Final Countdown to ICD-10…Tennessee Medical Group Managers Association

April 24, 2014

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• Understanding the new ICD-10 timeline

• Implementation steps for practice managers to ensure readiness for ICD-10 compliance

• Common vendor recommendations and available resources

• Brief ICD-10 overview

Agenda

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Understanding the new ICD-10 Timeline

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ICD-10 Timeline for Small-Medium Practices at a Glance

Source: http://www.cms.gov/Medicare/Coding/ICD10/Downloads/ICD10SmallMediumTimelineChart.pdf

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ICD-10 Timeline for Large Practices at a Glance

Source: http://www.cms.gov/Medicare/Coding/ICD10/Downloads/ICD10LargePracticesTimelineChart.pdf

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Updated ICD-10 TimelineStart Today

PYAMay June July Aug Sept Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec

PlanningIdentify resourcesCreate project teamAssess effectsCreate project planSecure budget

CommunicationsInform staffContact vendorsContact payersMonitor vendor prepMonitor payer prep

TestingHigh-level training for test teamLevel 1: internalLevel 2: external1

Comprehensive TrainingDocumentationCoding

2014 2015

Confirm ongoing practice schedule to correspond with new "go live" date

1Monitor external testing periods, especially updates regarding CMS limited testing currently scheduled for July 21 - 25, 2014 for selected volunteers.

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Implementation Process

Processes Reports Work Flow Information

Systems and Software

All Forms of Documentatio

n

Analysis of all Departments

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Priority ListBuy the ICD-10-CM Effective October 1, 2014 when released ~Sept 2013. (2014 Draft is available)

Make sure all of your systems are up-to-date

Billing should have access to both code sets to properly handle new and old claims

Consider an encoder or mapping resource if EHR or PM does not have mapping options

Update superbill with most used diagnosis codes

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• Administrators: Confirm capabilities, provide training, review processes

• IT staff: Confirm integration in system and documentation

• Providers: – Outpatient: Document in support of ICD-10 code selected– Inpatient: CM and PCS codes will have to be supported

• Billers: Understand how to look up codes, understand how to query physicians, pull new LCDs

• Coders: Understand ICD-10 guidelines and how to properly select ICD-10 codes based on documentation

Roles

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How much emergency cash should providers keep in case of cash flow disruption?• Review what happened to your practice with HIPAA 5010--this would be a good

baseline; with the transition of ICD-10 there will be delays in reimbursement • Vendors and Clearinghouses have been working hard, but we will not know the true

effects until the Compliance Date• The amount of money that you will need to set aside will be impacted by the

preparation work you do for ICD-10• It is recommended that you have up to several months' cash reserves or access to

cash through a loan or line of credit to avoid potential headaches• Will need to cover at a minimum practice operation expenses for three to six months:

– Medical supplies– Payroll– Rent

Budget

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Budget

• Cost of training/decreased staff productivity

• Cost of hardware/software upgrades

• Forms redesign

• Testing costs/Consulting services

• Vendor readiness – external testing

• Temporary maintenance of dual systems

• Cash reserves for denials increase, payment delays, decreased productivity

Determine financial impact, budget, resources, cash reserve needed for ICD-10 migration

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ICD 10 & EHR • Analyze EHR for functionality and compliance

• Review:

– Templates

– Interfaces

– Default documentation

– Level of detail

• Confirm EHR is updated with the ability to communicate to the billing system in ICD-10 language

– Is your PM integrated with your EHR?

– Look for products to include drop down menus and selection edits

– Need appropriate “granularity” to accurately capture correct code

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EHR Vendor Questions• Can EHR translate ICD-9 to ICD-10 format?• Can your EHR differentiate dates of service for

reporting ICD-9 or ICD-10?• Will ICD-9 code from previous visit translate in

new encounter as ICD-10?• Will system document ICD-10 on and after the

Compliance Date?• Are diagnoses linked from diagnostic results?• What are the capabilities of automated and

manual documentation entry?• Do you anticipate any pricing changes due to the

switch to ICD-10?

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Vendor ReadinessOur billing software vendor indicates they will be ready for these transitions. What can I do in the meantime, besides train for ICD-10 coding? • Ask your billing software vendor for a detailed schedule of deliverables

and begin preparing to test implementation of the modified software at your location.

• Be sure to verify the following:– The vendor is addressing the ICD-10 upgrades– The number and schedule of planned ICD-10 software releases– Their ICD-10 conversion plan accommodates your clearinghouse testing

schedule– Any related costs to your organization– Customer support and training they will provide

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Computer Assisted Coding (CAC)• Is this the answer?

– Select the right codes

– Ensure that those codes are justified and supported in the documentation

– Interface coded data correctly to billing systems

– Educate billing teams about appropriate codes

– Provide documentation and feedback/education to physicians

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Physician Work Flow • Will the EMR allow the physician to enter a

descriptive diagnosis rather than a specific diagnosis code?

• Is the physician prepared for the dramatic increase in diagnosis codes now displayed on the drop-down list?

• How will the physician’s workflow change when more time is needed to assign the appropriate diagnosis code?

• Can the EMR support a workflow that sends patient encounters to coders for review and assignment of the most specific diagnosis code based on the physician’s documentation?

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Superbill Changes – Fact or Fiction

ICD-10-CM-based super bills will be too long or too complex to be of much useFiction (sort of) • Practices may continue to create super bills that contain the most common

diagnosis codes used in their practice. ICD-10-CM-based super bills will not necessarily be longer or more complex than ICD-9-CM-based super bills. Neither currently-used super bills nor ICD-10-CM-based super bills provide all possible code options for many conditions.

• The super bill conversion process includes:– Conducting a review that includes removing rarely used codes.– Cross walking common codes from ICD-9-CM to ICD-10-CM, which can be

accomplished by using the General Equivalence Mappings (GEM) and looking up codes in the ICD-10-CM code book.

– Consider option of electronic super bill with posting scrubber that assist physicians in the transition to ICD-10. 

Source: http://www.whiteplume.com/learn-more/icd-10

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Payer’s Role• Communicate with your top payers to see

what, if any, ICD-10-CM changes will take place prior to the deadline– When will their testing begin?

– What will be required on your end?o Additional staff resources

– Prior authorizations granted for services to be performed after the Compliance Date

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Payer ResponseWill the ICD-10 conversion have an effect on provider reimbursement and contracting? • “Possibly. We are evaluating the impact of

ICD-10 on our contracting and clinical operations. The ICD-10 conversion is not intended to transform payment or reimbursement. However, it may result in reimbursement methodologies that more accurately reflect patient status and care.”

Source: http://www.aetna.com/healthcare-professionals/policies-guidelines/icd_10_faq.html

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What do I need to do to get theclaim out the door?

• Medicare will begin accepting a revised 1500 (version 02/12) on January 6, 2014 – Identify whether submitting ICD-9 or ICD-10 codes – Use as many as 12 codes in the diagnosis field

• Current limit is four

– Qualifiers to identify the following providers role (Item 17)• Ordering, Referring, Supervising

• Starting April 1, 2014, Medicare will accept only the revised version of the form– The revised form will give providers the ability to indicate

whether they are using ICD-9 or ICD-10 diagnosis codes

• http://www.cahabagba.com/news/medicare-accepting-revised-cms-1500-claim-form-0212-starting-april-1/

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What do I need to know to get the claim out the door?

• Reporting ICD-10 diagnosis codes• Claims Submission of diagnosis codes

– ICD-9 codes no longer accepted on claims with date of service after the Compliance Date

– ICD-10 codes will not be recognized/accepted on claims before the Compliance Date

– Claims cannot contain both ICD-9 and ICD10 codes--they will be returned as “Unprocessable”

• Date span requirements– Outpatient claims-split claim form and use from date– Inpatient claims-use only through date/discharge date for

ICD-10 code submission

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National Coverage Determinations (NCDs)

• CMS is responsible for converting approximately 330 NCDs

• Not all are appropriate for translation– Edits based on HCPCS– Older obsolete technology or

considered outdatedCMS has determined which NCD should be translated and is in the process of completing system changes for those NCDs

http://www.cms.gov/Medicare/Coverage/CoverageGenInfo/ICD10.html

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Local Coverage Determinations (LCDs)

• LCDs are developed by the individual Medicare Auditing Contractor (MAC – i.e., CAHABA)

• Contractors shall publish all ICD-10 LCDs and ICD-10 associated articles on the Medicare Coverage Database (MCD) no later thanApril 10, 2014

http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8348.pdf

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Code AnalysisReview top 20-50 diagnosis codes • Evaluate documentation currently in

the notes

• Crosswalk them to ICD-10

• Review new codes for additional required codes, additional code descriptions and “code also” requirements

• Identify areas where additional documentation will be required

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Once I get this claim out the door, am I going to get paid?

• The Department of Health and Human Services (HHS) anticipates that the percent of returned claims following the ICD-10 implementation could be more than double what we have seen in the past with ICD-9 updates.

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TrainingCoding and Billing Staff• Assess training needs and develop a plan

– Professional coding staff – ICD-10-CM– Determine who will train staff and how

this will be accomplished– Factor in time away from work, consider

post-testing and ongoing support– Make ICD-10 proficiency part of your

coding staff’s performance goals o ICD-9-CM to ICD-10-CM Dual Coding

• Assign staff members to be the “ICD-10 Experts” looking at the impact from the billing to the clinical side

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TrainingClinicians• Physicians – focus on codes germane to their practice

• Review clinical documentation improvement efforts and develop new strategies

• Incorporate documentation improvement as component to compliance training

• Ancillary staff – identify needs and level of training needed, nursing, financial services, quality, utilization, ancillary departments…

Information Technology• Training to ensure that codes are accurately cross-walked in organization’s IT systems

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What do certified coders need to do to get ready for ICD-10?

What is the ICD-10 Proficiency Assessment and is it required? (AAPC)• The ICD-10 Proficiency Assessment is the only step of this roadmap required for

all certified AAPC members. You should prepare yourself as you would for other exams or assessments. To ensure employers continue to have confidence in a certified coder’s ability to accurately code the current code sets, AAPC certified members will have two years to pass an open-book, online, unproctored assessment.– It will measure your understanding of ICD-10-CM format and structure, groupings

and categories of codes, ICD-10-CM official guidelines, and coding concepts.– Required for AAPC credentialed coders, (excluding CPPM®, CPCO™, and

CIRCC®), recommended for all others working with the new code set.– Two years to take and pass the assessment, beginning October 1, 2013, (one year

before implementation of ICD-10) and ending December 31, 2015, (current update)

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AHIMAIn order to validate that an AHIMA Certified Professional has gained knowledge of the ICD-10-CM/PCS coding system, CCHIIM has determined that continuing education hours with ICD-10-CM/PCS content will be required, as applicable and relevant to the specific AHIMA credential(s) held by the individual.• The total number of ICD-10-CM/PCS continuing education units

(CEUs) required, by AHIMA credential, is as follows:

*6 CEUs = 1 day of traininghttp://www.ahima.org/~/media/AHIMA/Files/Certification/ICD10_CEU_FAQs.ashx

– CHPS – 1 CEU– CHDA – 6 CEUs– RHIT – 6 CEUs– RHIA – 6 CEUs

– CDIP – 12 CEUs– CCS-P – 12 CEUs– CCS – 18 CEUs– CCA – 18 CEUs

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Resources Available• http://www.cms.gov/Medicare/Coding/ICD10/index.html

• http://www.ahima.org/icd10/

• http://www.aapc.com/icd-10/index.aspx

• http://www.cdc.gov/nchs/icd/icd10.htm

• http://www.who.int/classifications/icd/en/

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Where can I Find the ICD-10-CM Codes?

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• Partial solution--these are tools to convert ICD-9 to ICD-10 and vice versa.

• To assist with the transition, cross-walking between the code sets will assist you with identifying the differences between ICD-9 and ICD-10.

• Not a high percentage of accuracy due to increased complexity of ICD-10 versus ICD-9

Crosswalk

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GEMsGEMs are a comprehensive translation dictionary that can be used to accurately and effectively translate any ICD-9-CM-based data, including data for:

– Tracking quality

– Recording morbidity/mortality

– Calculating reimbursement

– Converting any ICD-9-CM-based application to ICD-10-CM/PCS

The GEMs are not a substitute for learning how to use the ICD-10 codes. More information about GEMs and their use can be found on the CMS website at:

• http://www.cms.gov/Medicare/Coding/ICD10/index.html

(select from the left side of the web page ICD-10-CM or ICD-10-PCS to find the most recent GEMs)

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Practical Mappings GEM Examples – ICD-9 to ICD-10

ICD-9-CM: 902.41 Injury to renal artery

ICD-10-CM GEM: S35.403A Unspecified injury of unspecified renal artery, initial encounter

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How Does the Mapping Work?

ICD-9-CM• 493.92 Asthma,

Acute Exacerbation

ICD-10-CM• J45.21 Mild, intermittent,

w/acute exacerbation

• J45.41 Moderate, persistent, w/acute exacerbation left

• J45.51 Severe, persistent, w/acute exacerbation

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Percentages of Types of MatchesMapping

CategoriesICD-10 to

ICD-9ICD-9 to ICD-10

No Match 1.2% 3.0%

1-to-1 Exact Match 5.0% 24.2%

1-to-1 Approximate Match with 1 Choice 82.6% 49.1%

1-to-1 Approximate Match with Multiple Choices 4.3% 18.7%

1-to-Many Matches with 1 Scenario 6.6% 2.1%

1-to-Many Matches with Multiple Scenarios 0.2% 2.9%

Source: http://www.ama-assn.org/ama1/pub/upload/mm/399/crosswalking-between-icd-9-and-icd-10.pdf

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What does ICD-10-CMlook like?

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ICD-10-CM Organization

Index to Diseases and InjuriesOfficial Guidelines

Tabular List of Diseases and

Injuries

The CM Manual divided into three main parts:

21 Chapters

Expanded injury codes grouped by site vs. type

of injury

Laterality (left and right)

V and E codes incorporated into

main classification

Added a placeholder X

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Anatomy of an ICD-10-CM Code3-7 Alphanumeric characters (digits)

X X X X X X X.

1st character – Alpha (A-Z)

2nd character - Numeric

3rd - 7th characters –

Alpha or Numeric

Decimal placed after the first 3

characters

• All letters but U are used• The letters I & O are used only in the 1st character position• Each letter is associated with a particular chapter (Except C&D

Neoplasms )

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X X X X

Category

.Etiology, anatomic

site, severity

Added code extensions (7th character) for

obstetrics, injuries, and

external causes of injury

ICD-10-CM Characters and Extensions

X X XAMS 0 2 6. 5 x A

Alpha (Except U)

2 - 7 Numeric or Alpha

Additional Characters

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• X Marks the Spot– ICD-10-CM uses a placeholder character

“X” this will allow the code future expansion– Where a placeholder, the X must be used in

order for the code to be valid (The X is not case sensitive)

XPlaceholder Character

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7th Character Extension• Certain ICD-10-CM categories have a 7th character

feature; this “character” must always be in the 7th character field

• These extensions are found predominantly in two chapters– Chapter 19 – Injury, Poisoning and Certain Other

Consequences of External Causes

– Chapter 15 – Pregnancy, Childbirth and the Puerperium

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If a diagnosis code requires a 7th digit and the code is a

4-digit code, what do you do?

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Place an x in the 5th and 6th digitICD-10-CM utilizes a placeholder: Character “x” used as a 5th character placeholder in certain 6 character codes

• To fill in other empty characters (e.g., character 5 and/or 6) when a code that is less than 6 characters in length requires a 7th character

Examples: • T46.1x5A – Adverse effect of calcium-channel blockers, initial encounter

• S03.4xxA- Sprain of jaw, initial encounter

• T15.02xD – Foreign body in cornea, left eye, subsequent encounter

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TMGMA ResourceTennessee MGMA has partnered with PYA to provide an ICD-10 user’s group for TMGMA members. • ICD-10 updates webinar: Friday, May 16,

noon to 1 pm CDT• Ongoing user’s group list serve support for

ICD-10

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Questions?

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Thank you!

Linda ClenDeningConsulting Manager

Pershing Yoakley & Associates, P.C.(865) 684-2735

[email protected]

Valerie RockConsulting Manager

Pershing Yoakley & Associates, P.C.(404) 266-9809

[email protected]