ICD-10 Info Series Part 2

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.

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.