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Regulatory MonitoringArchive for August, 2008
Last week was a relatively light week on the regulatory front with one significant exception. As reported below, last week CMS issued a proposed rule on the replacement of ICD-9-CM with ICD-10-CM (diagnosis codes) and ICD-10-PCS (procedure codes) effective October 1, 2011. Over the years, we have had numerous false starts on the implementation of ICD-10. So, it remains to be seen whether the proposed rule will really be finalized and, if so, whether the implementation date will remain October 1, 2011.
If this really is the beginning of the implementation process of ICD-10, hospitals should not underestimate the operational implications. ICD-10 is much more that an enhancement of ICD-9-CM. Rather, ICD-10-CM and ICD-10-PCS are completely different coding systems from ICD-9-CM. Computer systems will need significant reprogramming and hospital staff will need extensive retraining. Many people remember the operational challenges presented by the so-called “Y2K” transition. In my view, Y2K was a “walk in the park” compared to the challenges that will be presented by the implementation of ICD-10. We should all review the proposed rule carefully, submit comments as appropriate, and keep a close eye on this process.
On August 15, HHS proposed to adopt the ICD-10-CM and ICD-10-PCS code sets to replace the ICD-9-CM code set, effective October 1, 2011.
View the proposed rule.
View a related press release.
View the “Transaction and Code Sets Standards” pages on the CMS Web site.
RAC team members should not be limited to one specific area, says William Malm, ND, RN, president of Health Revenue Integrity Services, Inc.
“Team members should represent all facets of the revenue cycle,” he says.
Specifically, he says, team members should include:
- Patient access representatives
- Chargemaster coordinators/analysts
- Physician advisors
- Revenue integrity auditors
- Denial management personnel
- Clinical staff
- Compliance staff
- Inpatient and outpatient coding staff
- Case management staff
- Utilization review staff
- Patient financial services/billing staff
For a copy of Malm’s white paper on RACs, click here.
To prepare for the nationwide rollout, it’s important to get your appeals process in place, says Linda Fotheringill, Esq., an attorney who specializes in overturning RAC appeals and Medicare denials.
“You need to fight back or you’re going to have a target on your head,” says Fotheringill, a founding member of Washington & West, LLC, in Baltimore, MD, and the law firm of Fotheringill & Wade, LLC. “If not, it increases the likelihood [RACs] are going to continue going there.”
Fotheringill offers the following tips on establishing your appeals process:
1. Make sure that you have a process in place to recognize a notice of denial and that a team is in place to take action in a timely fashion.
2. When sending in a medical record to appeal, send the entire record. Do not take abstracts and bits and pieces.
3. Make sure the reviewer has received training in how to analyze a case with relevant Medicare regulations.
Editor’s note: The preceding is an excerpt from the upcoming September edition of HCPro, Inc.’s newsletter, Patient Access Advisor. To learn more about Patient Access Advisor, click here.
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