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If at first you don’t succeed: New bill aims for ICD-10 delay again

If nothing else, Rep. Ted Poe, R-Texas, is consistent. He again introduced legislation to kill ICD-10. (The bill is H.R.2126 if you are interested.)

Poe has tried this trick before. He introduced an almost identical bill April 24, 2013. That bill, H.R. 1701, was never even discussed in committee.

Members of the House Energy and Commerce Committee’s Subcommittee on Health seemed to agree that we need ICD-10 during the February 11 ICD-10 implementation hearing. So it seems unlikely that this bill would make it very far.

Six fellow Republicans signed on as cosponsors of the bill, but the Democrats seem to be staying away. More indication that this bill is a non-starter.

With less than five months to implementation, we don’t need this kind of distraction. What we need are assurances that another delay won’t happen. Sadly, we probably won’t get the date written in stone and most of us will probably remain skeptical. It’s okay to be a skeptic. Just don’t slow down your ICD-10 implementation work because you think Poe might get a bill heard.

Editor’s Note: This article originally appeared on the ICD-10 Trainer Blog.

ICD-10 Tip of the Week: Follow a timeline for preparation

Don't delay! Start preparing for ICD-10 now.

Don’t delay! Start preparing for ICD-10 now.

We get it: It’s been a challenge to maintain a proper ICD-10 education and preparation schedule with the delays, the doubts, and the everyday challenges that already exist without the stress of a new code set. But, as CMS insists that ICD-10 is a go, it’s time for facilities to nail down a plan of action. There are a lot of changes, and the best way to ensure a smooth transition is organization.

This is why ACDIS, with the help of director, Brian Murphy, and the ACDIS advisory board, created a sample ICD-10 training and implementation timeline for CDI specialists. It includes recommended courses of action, the most important element being fostering facility-wide communication. Facilities throughout the country are also used as case studies, so you can see what’s worked—and what hasn’t worked—for existing CDI departments that are already preparing for the October 1, 2015 implementation date.

The biggest challenge many facilities face is, “where to begin?” With open communication at the center of any preparation plan, the first step is ensuring organizational understanding of the impact of ICD-10, says Michelle McCormack, RN, BSN, CCDS, CRCR, ACDIS advisory board member and director of CDI for Standard Hospital and Clinics in Palo Alto, California. Include hospital and departmental leadership in meetings and related educational sessions. Or set up ICD-10-focused committees in charge of coordinating education, evaluating preparedness, and the like. All in all, it should be a hospital-wide effort.

Identifying weaknesses in documentation efforts is also something to be looked at early on, says Laurie Prescott, RN, MSN, CCDS, CDIP, CDI education specialist with ACDIS/HCPro in Danvers, Massachusetts. For example, many facilities struggle with procedure codes (ICD-10-PCS), in part due to the increased specificity. However, if there is a larger focus on PCS codes now, CDI specialists can provide targeted education regarding top procedures and current documentation practices.

The ACDIS timeline focuses on dual coding practices, which Prescott says is critical to a successful transition. There should be a feedback loop between coders and CDI specialists to communicate what information is missing and what is required. CDI specialists should also identify specific documentation needs for specific physicians.

Query policies should also be reviewed, Prescott adds. They should reflect the fact that more queries will be asked in ICD-10, and should include how queries will be prioritized, how long queries are allowed to be unanswered, and how to differentiate between queries for reimbursement, and those that provide more specificity but do not affect reimbursement.

When designing a timeline for your own facility (we recommend using the ACDIS timeline as a guide), start by listing the remaining months before implementation, and creating goals and to-do lists for each month. Once you have a plan in place, circulate it throughout your facility, and make sure hospital leadership is aware of your plans, as well as any scheduled training sessions or meetings.

Here’s an example of what May ICD-10 preparations might look like. Keep in mind, this timeline begins at the end of 2014. If your facility has not yet started its ICD-10 prep, take a look at the timeline as a whole, and figure out a reasonable schedule that works for your team.

May 2015

  1. Full dual coding scope, use external vendors to supplement staffing as needed. Solidify and execute staffing plan (internal and external) to meet ICD-10 productivity and quality standards, and maintain accounts receivable.
  2. Continue analysis of dual coding outcomes. Task CDI with tailoring and presenting service-specific education based on the findings.
  3. Develop “go-to” team with coding counterparts in preparation for go-live.
  4. Provide fact sharing and status update to ICD-10 transition teams; adapt as needed.

Editor’s Note: The previous information was compiled from a variety of ACDIS resources. For additional information, check out:

ICD-10 Tip of the Week: Know the basics

Got a question? Ask us!

The problem many facilities face with ICD-10 prep is that they don’t know where to begin.

It might seem pretty obvious that, with a new code set and code structure, your team should probably understand what’s going to change. The problem many facilities face is that they don’t know where to begin.

Practicing with the new code set could make all the difference to CDI and coding success post-implementation. As CDI specialists, knowing some of the code set basics can help you understand what is needed in the documentation, and can help prevent claim errors. So let’s go back and review some of the ICD-10-CM basics.

ICD-10-CM (diagnosis codes) far exceeds ICD-9-CM in the number of concepts and codes available. Here are some key differences:

  • ICD-10 codes will be 3-7 characters in length, as opposed to 3-5 characters for ICD-9
  • 69,000 codes available in ICD-10, as opposed to 13,500 codes in ICD-9
  • ICD-10 is flexible for adding new codes, very specific, and has laterality, while ICD-9 has limited space for new codes, lacks detail, and lack laterality

The additional characters allow for more specificity particularly anatomically and in regards to laterality. If the diagnosis does not have such a code, both right and left codes for the condition should be reported.

As far as the code structure goes, under ICD-10, codes will no longer begin with a letter “E” or “V,” as they did in ICD-9. The first character is always a letter, the second and third are numbers, and the fourth through seventh characters can be either or. CDI specialists and coders will also need to avoid confusing the letter “O” with the number zero (0), and the letter “I” with the number one.

Some other things that CDI specialists will need to be aware of include the location of the characters—this now matters, specifically for the 7th character which can indicate additional information such as the episode of care (Learn more about this in the forthcoming May edition of the CDI Journal, as the AHA Coding Clinic for ICD-10-CM/PCS covered this in some depth during a recent volume.

ICD-10 also uses the letter “X”, for codes that require a 7th character, but which have less than seven characters as a placeholder. Read more about placeholder use in the CDI Specialist’s Guide to ICD-10.

This might seem a bit rudimentary, especially for those facilities that have been incorporating ICD-10 education into their ongoing training already, but having a strong foundation of ICD-10 knowledge is critical. Knowing the basics will allow CDI specialists to assist physicians in ensuring their documentation is specific enough for proper coding, and to facilitate coders in retrospective reviews.

Editor’s Note: The previous information was compiled from a variety of ACDIS resources. For additional information, check out:

I said what I meant and I meant what I said

Rumors upon rumors keep ICD-10 prep from progressing. Don't let the hearsay stop your efforts

Rumors upon rumors keep ICD-10 prep from progressing. Don’t let the hearsay stop your efforts

We want physicians to be very clear in their documentation about what’s wrong with the patient and what the physician did to make that patient better. CDI Specialists spend their professional lives working to get more precise, detailed, accurate, no-room-for-interpretation documentation.

Why all the fuss about specificity? Different people interpret things different ways. My colleagues sometimes hate me for playing devil’s advocate and saying, someone could take that to mean Y instead of X.

Relevant case in point: Earlier this week, AHIMA emailed its members imploring them to call members of Congress to oppose an ICD-10 delay. AHIMA’s Margarita Valdez, senior director of Congressional relations, heard that Chairman of the House Rules Committee Pete Sessions, R-Texas, was drafting (or looking to draft) language for another ICD-10 delay.

My colleague Steve Andrews reached out to Sessions’ office asking for verification. In very short order, a member of Sessions’ staff replied that the Congressman is meeting with physicians about their concerns regarding ICD-10, but no legislation has been drafted.

I also heard from a blog reader who told me she had spoken to a staff member for Rep. Rob Woodall, R-Ga. That staff member had spoken to Sessions’ staff, who told him that Sessions has no plans at present to introduce legislation for another delay of ICD-10. (That’s a massive amount of hearsay, because it’s at best fourth-hand information, but still, we’ll take what we can get for now.)

At first glance, that looks like a win. No legislation, no delay, right? Not exactly. Here’s where playing devil’s advocate comes in.

Sessions had not drafted legislation and has no plans to introduce legislation. However, no one claimed Sessions isn’t looking to add language to an existing (or future) bill to delay ICD-10. It’s nitpicking, but we are talking about politicians.

The whole discussion may have started with a letter that the AMA and 99 specialty societies sent to Andrew Slavitt, acting administrator of CMS, detailing a “number of concerns that do not appear to be addressed” by CMS’ current transition plan.

Fair enough, we’re all worried about certain parts of the transition.

The medical groups want CMS to release more detailed end-to-end testing results broken out by:

  • Type and size of providers who tested
  • Number of claims tested by each submitter, percentage of claims successfully processed
  • Specific details about problems encountered

That seems reasonable to me. The more we know about what worked and what didn’t, the better we can prepare.

Things get a little murkier near the end of the letter when it talks about code specificity. The AMA has been beating this drum for a while now because the increased specificity requires more detailed documentation. The detail, though, is one of the main strengths of ICD-10. We can get a better picture of the patient’s health, and with ICD-10-PCS, we’ll actually know what specific procedure the physician performed.

According to the letter:

CMS officials have stated that, absent indications of potential fraud or intent to purposefully bill incorrectly, CMS will not instruct its contractors to audit claims to verify that the most appropriate ICD-10 code was used. There is also general concern about how physicians will be audited as they learn to use the new code set. We urge CMS to: 1) confirm and broadly educate stakeholders and contractors that claims will not be audited simply for code specificity; and 2) to instruct contractors that they are prohibited from engaging in audits that are only predicated on code specificity.

I was kind of appalled by the apparent unconcern for specificity. Then I reread it and found it’s not so much appalling as it is vague. Then I went back to the source of the “no audit” statement, the Government Accountability Report on CMS’ preparation for ICD-10 implementation. According to that report:

CMS officials stated that the submission of valid ICD-10 codes is a requirement for payment; however, when the presence of a specific diagnosis code is not required for payment then the claim would be paid even if a more appropriate ICD-10 code should have been used on the claim.

In a way that makes sense. You could go to the physician’s office for a cold or a bad cut or just for your annual physical. In order to use the CPT® code for an office visit, you don’t need a particular ICD-10-CM code. You just need the code that will support medical necessity for that service. So if a patient is seen for S50.311A (abrasion of right elbow, initial encounter), you probably won’t get away with reporting CPT code 99215 (level 5 established patient visit).

The GAO report further stated:

Additionally, CMS officials indicated that, absent indications of potential fraud or intent to purposefully bill incorrectly, CMS will not instruct its contractors to audit claims specifically to verify that the most appropriate ICD-10 code was used. However, audits will continue to occur and could identify ICD-10 codes included erroneously on claims which could lead to claims denials, according to CMS officials.


News: AHIMA says House Representative looking to delay ICD-10

CMS says new date for ICD-10-CM/PCS implementation set for 2015.

CMS says new date for ICD-10-CM/PCS implementation set for 2015 but will that date hold?

Just when we were starting to feel really good about ICD-10’s chances of being implemented, AHIMA has learned that Chairman of the House Rules Committee Pete Sessions, R-Texas, is looking to draft language to delay ICD-10. The chairman is seeking support from his colleagues in Congress, according to an email from Margarita Valdez, senior director of Congressional relations for AHIMA.

AHIMA is urging HIM professionals to call Rep. Michael Burgess, R-Texas, at (202) 225-7772 and state that you support ICD-10 implementation in 2015.

Here are some talking points from AHIMA:

  • We need the code sets in 2015!
  • A recent GAO report supports ICD-10 readiness.
  • Small physician practices are expected to spend between $1,900 and $6,000 to transition to the new code set. This is much lower than previous reports. The study can be found on

You can also mention the House Energy and Commerce Committee’s subcommittee on health’s ICD-10 Implementation hearing February 11. During the testimony, the subcommittee’s members heard from seven industry stakeholders, six of whom supported ICD-10 implementation in 2015. Many members of the subcommittee agreed that the U.S. needs ICD-10, and it should not be delayed any further.

Then call the other congressional leaders also. AHIMA helpfully provided their names and phone numbers:

  • Sessions: (202) 225-2231
  • Rep. Virginia Foxx (R-North Carolina): (202) 225-2071
  • Rep. Tom Cole (R-Okla.): (202) 225-6165
  • Rep. Rob Woodall (R-Ga): (202) 225-4272
  • Rep. Steve Stivers (R-Ohio): (202) 225-2015
  • Rep. Doug Collins (R-Ga): (202) 225-9893
  • Rep. Louise Slaughter (D-NY): (202) 225-3615

If you tweet, you can also find their Twitter handles very easily online, for example, @michaelcburgess and @PeteSessions.

Make sure Congress knows we support ICD-10 in 2015!

Editor’s Note: This article was originally posted on our sister blog the ICD-10 Trainer

News: CMS’ first round of end-to-end testing a success

news blocksAdd another nail in the “delay ICD-10 because the industry isn’t ready” coffin.

CMS declared its end-to-end testing week from January 26 through February 3 a success. A total of 661 volunteers submitted 14,929 test claims, with CMS accepting 81% (12,149 claims).

CMS rejected 13% of the claims for reasons not related to ICD-10, such as:

  • Incorrect National Provider Identifier
  • Dates of service outside the range valid for testing
  • Invalid HCPCS codes
  • Invalid place of service

Three percent of claims contained an invalid ICD-10-CM and 3% had an invalid ICD-10-PCS codes, leading CMS to reject the claims.

More than half (56%) of the claims fell under professional services and 38% were institutional claims. Suppliers submitted 6% of the claims.

CMS identified zero issues related to professional and supplier claims and stated that none of the claims were rejected because of front-end submission problems.

CMS did find one system issue related to institutional claims, but it affected fewer than 10 total claims. It will fix the problem before the next end-to-end testing week April 26-May 1.

Editor’s Note: This article originally published on the ICD-10 Trainer Blog.