Archive for August, 2011
ICD-10 Info Series Part 2
Aug 9th
Welcome back! I hope that you enjoyed my last post about an overview of ICD-10 implementation. Well get ready, because today’s post covers the basic steps to comply with ICD-10 implementation as detailed by CMS.
To CMS’s credit, there is no under exaggeration of the complexities and challenges that ICD-10 implementation will create. To this end, CMS suggests that planning for the transition to ICD-10 from ICD-9 should occur well advance of the October 1, 2013 deadline. Now if you are anything like me, you may feel that because the transition date is more than two years away that it is too soon to start any compliance plan. A lot can happen in two years, right? No. I cannot emphasize enough CMS’s seriousness of the October 1, 2013 deadline. At least starting to think about a plan today will avoid your practice many headaches in the future. Please don’t call me on September 30, 2013 asking to help you update your superbill.
Let’s get down to the basic steps your practice can take to comply with the ICD-10 implementation.
- Identify the current systems and work processes that use ICD-9- Makes sense, right? You must first identify the areas of your practice that will be affected before you can implement a compliance plan. According CMS, some of these areas may include clinical documentation processes, practice management software, electronic health record systems and of course the ubiquitous superbill. Furthermore, you may feel that some of these processes need to be adjusted or outright abandoned to comply with ICD-10 implementation. Identifying these processes now will allow a more educated compliance plan.
- Talk with your practice management system vendor/billing service/clearinghouse about accommodations for both Version 5010 and ICD-10 codes- This is a very important step to take because there is always an assumption that your revenue cycle company/software vendor knows what they are doing. However, this may not always be the case. Be sure to ask the vendor if they are planning any updates and the schedule when the updates will be included. Additionally, review your service contract to see if all of the updates are included or if they are extra services that you will have to pay for. Don’t assume a thing.
- Contact your major payers to determine if ICD-10 will cause changes in your reimbursement contracts- CMS points out that because ICD-10 is so much more detailed than ICD-9, payers might modify payment schedules and contracts. Be careful to understand how the payers are reacting to ICD-10 because inevitably their response will affect you.
- Assess staff training needs- Your staff is very important to your practice and will have the most interaction with many of these new codes. Identifying the appropriate staff members that need ICD-10 training is key. Consequently, inherent in new training is cost and creative budgeting will be necessary. If you have a small practice you may be able to hold joint training sessions with other practices to increase the cost effectiveness of training sessions. You can also ask your billing service provider to provide training if it is offered. CMS suggests that new training should be completed six months prior to the implementation date of October 1, 2013.
- Conduct 5010/ICD-10 submission tests with all payers and clearinghouses- Last but not least, this step is one that can be embarked upon relatively soon. As I Mentioned in my previous article, the deadline for 5010 compliance is January 1, 2012. Most, if not all, payers and clearinghouses are currently accepting test submissions to ensure compliance with 5010 standards. As for ICD-10 submissions, you may have to wait a little bit to send a test file but it would be in your interest to remain in contact with your payers and clearinghouses to find out when ICD-10 test submissions will be accepted.
There is no harm in starting your compliance plan early, just don’t start it now and forget about it come 2013. A consistent and measured approach to ICD-10 implementation will allow you to focus on what you do best- care for your patients.
For more information, please feel free to visit https://www.cms.gov/ICD10/05a_ProviderResources.asp#TopOfPage.
Brendan P. Harney, Associate General Counsel
Mr. Harney joined MTBC in 2010 as an Associate General Counsel. His practice mainly focuses on healthcare compliance regulations including HIPAA and state privacy laws.
HHS Proposes Access Report for Patients: Proposed changes to HIPAA Privacy Rule
Aug 8th
The Department of Health and Human Services (HHS) is now reviewing comments from healthcare industry participants about its proposed rule to modify the standard for accounting of PHI disclosures under the HIPAA Privacy Rule. HHS has proposed revising the Privacy Rule by dividing it into two separate rights for individuals: the right to an access report of disclosures through electronic medical records; and the right to an accounting.
Under the Proposed Rule, covered entities would now be required to provide individuals with an “access report,” identifying all persons who have accessed an individual’s electronic “designated record set” information. The designated record set is the group of records maintained by or for a covered entity that is either (1) used, in whole or part, to make decisions about individuals; (2) a provider’s medical and billing records; or (3) enrollment, payment, claims, adjudication, and case or medical management record systems maintained by or for a health plan. This new access report applies only to electronic records and is intended in part, to fulfill a requirement established by the Health Information Technology for Economic and Clinical Health Act (HITECH) to provide individuals with information about disclosures of their PHI to carry out treatment, payment and health care operations if such disclosures are through an electronic health record.
Distinct from, but complementary to the access report is the proposed right to an accounting. While the access report would provide information on who has accessed the individual’s electronic PHI, the accounting would provide additional information about the disclosure of the “designated record set” information to persons outside the covered entity and its business associates for certain purposes, such as law enforcement, or public health investigations. The purpose of the access report is to allow individuals to learn if specific persons have accessed the individual’s electronic designated record set information. The accounting disclosure, on the other hand is intended to provide more detailed information for certain disclosures that are most likely to impact the individual.
The deadline for submitting a comment to be considered by HHS was August 1, 2011. The Final Rule will be published after HHS has reviewed, analyzed and if necessary responded to the comments, which can be viewed at:
Christine Salimbene, Vice President & General Counsel
ICD-10 Info Series – Part 1
Aug 3rd
An old saying goes that “laws are like sausages, it is better not to see them being made.” The decision to transition from ICD-9 to ICD-10 by the Center for Medicare and Medicaid Services (CMS) is no exception to this saying and most likely the finished product will not be appetizing to most healthcare providers either.
To first comply with this regulation you must first know what it actually means to your practice. ICD-10’s goal is to assist providers in adapting to the changing and more detailed world of modern disease diagnosis. To accomplish this feat, ICD-10 will include almost 69,000 diagnosis codes compared to 13,000 ICD-9 codes. Many of these new codes reflect changes in medical diagnosis but the majority attempt to provide a more specific and in depth classification of existing aliments.
This transition will inevitably mean more cost to healthcare providers who must now find the regulation, understand it and implement a training regime so that their practices are in compliance. This burden is especially heavy on smaller practices that do not have the administrative infrastructure that larger practices and hospitals currently have in place.
Now you may believe that your practice is not subject to the new 1CD-10 codes or that you are immune because you receive reimbursement from only commercial insurance payers. Denial is always present when uncomfortable change is developing. Please take heed though, that all “covered entities” under HIPAA are subject to ICD-10. This includes healthcare providers, all payers (commercial and governmental) and other entities such as software vendors and billing companies. Denial is a necessary step to acceptance and eventually compliance.
CMS has set several deadlines for providers to comply with the new regulation. First, all electronic claims must conform to HIPAA transaction 5010 standards by January 1, 2012. This change establishes the technical groundwork for the use of ICD-10 codes, which become mandatory on October 1, 2013. If you are not a big believer in bureaucratic efficiency and believe that these dates will inevitably be extended (as they already were extended for 2 years in 2009), please note that CMS is adamant that there will be no further extensions to these deadlines.
To further buttress this point, CMS has even begun sponsoring training events such as the sardonically named Code-a-thon in April of 2011. CMS is also providing national provider conference calls and training materials to attempt a smooth transition from ICD-9. All evidence is pointing to CMS’s seriousness in this transition. Developing a plan for your practice now will blunt any of the hardships that will arise once full implementation of ICD-10 occurs in October of 2013. Because as with anything coming out of Washington, the devil is always in the details.
This is just Part 1 of my discussion on ICD-10 implementation.
Be sure to read my next blog post in which I will discuss the steps your practice can take to comply with 1CD-10.