Countdown to ICD-10 – Are you Ready?

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The CMS MLN Connects™ Call Program has a variety of online resources to get you started down the road to ICD-10 proficiency. Check out the Calls and Events web page for slide presentations, audio recordings, and written transcripts, from previous ICD-10 educational conference calls, or view one of our popular ICD-10 educational video programs. Read, listen, or view these information packed programs at your convenience to learn more about implementing ICD-10 in your workplace.

For the latest information on ICD-10, visit the CMS ICD-10 dedicated website, including the Medicare Fee-For-Service Provider Resources web page for a list of resources developed under the Medicare Learning Network ® (MLN).

Have an ICD-10 Coding Question? Visit the HBMA Message Board on Coding

HBMA Message Boards give members the ability to leverage the collective knowledge of the association’s membership to answer your specific ICD-10 questions. Visit the HBMA Coding Message Board to post your question or search the repository of previously submitted/answered questions. In addition to the message board on coding, HBMA also offers message boards on the following topics: compliance, electronic health records and practice management. The entire collection of Members Only Message Boards is available via the HBMA website.


1. Will ICD-10 be postponed again?
There is little to no chance of another postponement. CMS has been aligning resources and putting together implementation plans with every intent of going live October 1, 2014. Work has begun on NCDs. End-to-End testing plans are being developed.

2. ICD-10 is only months away. What do I need to do to prepare?

a. Seek out ICD-10 resources: HBMA ICD-10 Committee, CMS website, payors and vendors.

b. Create an internal ICD-10 team.

c. Consider the potential for disruption of cash flow and plan accordingly.

d. Identify all processes that involve the transfer of diagnosis code data.

e. Review all current forms, requisitions, etc., to assess changes required for ICD-10.

f. Locate and provide resources to physicians to teach them how to document adequately to code ICD-10.

g. Locate and provide resources to coders to teach them how to code ICD-10.

h. Set aside a few hours per month for coders to code current charts using ICD-10 codes.

i. Contact all vendors to obtain their ICD-10 plans.

3. My vendor (Practice Management (PM) System, Computer Assisted Coding System, Electronic Health Record, etc.) says they are ICD-10 compliant. Am I ready?
Challenge the vendor. No application can consider themselves compliant until they have obtained, maintained, transmitted, and audited ICD-10 codes in a production environment. At best, a vendor can say they are ICD-10 enabled.

4. I have multiple software applications that touch diagnosis codes. Should I be concerned about their readiness? After all, that’s their job.
All vendors should have a plan for accommodating ICD-10 codes. This includes any programming, testing, and implementation procedures. If the vendors have not provided their plans via bulletins, meetings, or other forms of communication, contact them. Ask about system updates, associated fees, timelines, and testing plans.

5. I use a Computer Assisted Coding software application. Since coding is the backbone of their software, should I be concerned?
Yes. Contact the vendor to see when they will be ready to test with ICD-10 codes. Upon receipt of coded services, audit them to determine if the codes they assign are the same as manually assigned codes.

6. What will I have to test on my PM System?

a. This depends on the processes you currently use:

i. Demographic data Capture from hospital systems, facilities, and EHR software will require testing if diagnosis codes are transmitted.

ii. Charge capture from Computer Assisted Coding applications, facilities, and EHR software will require testing as diagnosis codes are a required value for all charges.

iii. PM Systems must be tested for claim submissions and remittance/denial processing (ANSI 837/835).

iv. If you send and receive eligibility/authorization files (ANSI 270/271), these should be tested.

v. If you send and receive claim status requests/responses (ANSI 276/277), these should be tested.

vi. Internal data warehouses should be tested if diagnosis data is included.

vii. Internal reporting should be reviewed.

7. Isn’t this just a software update? Can’t my PM System do all of the testing?
The PM system will test the ability to receive and transmit the data, but the actual testing process must be done from your facility using real patient data.

8. If I pass the test with Medicare, do I have to test with anyone else?
Review the practice’s payor mix. Be prepared to test with the major payors and clearinghouses. Many payors are requesting a test file of no fewer than 20 claims for a sampling of their members.

9. I am a billing service providing revenue cycle management for a wide variety of practices and specialties. Do I have to test with each of them?
Be prepared to test each specialty, not necessarily each practice.

10. Can I just test random claims?
Yes, but a more focused approach would be beneficial. Test some claims with the most common diagnoses utilized by the practice. Test some claims with diagnosis codes that are frequently denied. Test some claims that have been denied using ICD-9 codes to determine the effect of ICD-10.

11. Will all payors be ICD-10 ready on October 1, 2014?
HIPAA covered entities are supposed to be ready to accept and process charges with dates of service as of October 1, 2014 using ICD-10 codes. Based upon ANSI-5010 readiness back in January 2012, it is difficult to say whether all payors will be ready or not. Contact payors to obtain their state of readiness and testing plans. They must still be able to receive and process charges (and resubmissions) with dates of service before October 1, 2014 using ICD-9 codes. Practices must be able to transmit both sets of codes based upon the payor and service date. Entities not covered by HIPAA (Workers’ Compensation, No-Fault, Auto) have stated they probably will not transition to ICD-10 until much later, if ever.

12. My clients will have EHRs by October 1, 2014 that will have ICD-10 loaded. Shouldn't that make it easy for them to choose a diagnosis code?

There will be over 67,000 codes to choose from. Many doctors use acronyms and general terminology that will not be easy to find. They will have to become familiar with the structure of ICD-10 codes and specific codes used in their specialties prior to implementation and then develop a "favorites" list.

13. What should my system vendor do to ensure readiness?

It is imperative that your vendors communicate with all other systems and vendors with which they interface or exchange data. Different vendors may, and likely have, made proprietary or other business decisions on the methodologies that will be used to handle the transition from ICD-9 to ICD-10. Examples include, using DOS to make ICD version decisions or mapping and/or crosswalk methodology such as GEMS. It is important to know how each data trading partner will be handling ICD data so that your systems (PM, EHR, etc.) can continue to successfully share data with them.