We almost made it unscathed. We’ve upgraded, tested, trained and upgraded again. We rewrote reports and interfaces and assessed financial risks. While cautious, many organizations were coming to grips with the ICD-10 gaps they needed to fill by Oct. 1. Then came the announcement: “CMS and AMA Announce Efforts to Help Providers Get Ready for ICD-10.”
The agreement, unveiled July 6, was a response to requests from the provider community and allows for flexibility in the “claims auditing and quality reporting process” as the medical community builds experience with the new ICD-10 code set, according to the release.
So, technically, no ICD-10 was not canceled or delayed, but it was in some ways watered down and the announcement has injected confusion into the process. Many in the physician community feel they have gotten a reprieve from ICD-10. Language regarding “family of codes” and exemption regarding “specificity” have many scratching their heads. This confusion has prompted the Centers for Medicare & Medicaid Services to post clarifying language on its website and issue FAQs.
As with all things, ultimately the devil is in the details. In reviewing CMS’ clarifications, proper coding is still required and CMS notes that, “In certain circumstances, a claim may be denied because the ICD-10 code is not consistent with an applicable policy, such as Local Coverage Determinations or National Coverage Determinations.” Regardless, there are still a number of questions and issues with this flexibility position.
While it appears there is flexibility on the part of the physicians, there does not appear to be any such flexibility for hospitals and other health care organizations. As hospital providers, we are at the mercy of what our physicians order and the codes that are part of those orders. A nonspecific code may be acceptable for physician billing, but it is still not acceptable for hospital billing.
In our organization, this flexibility is a problem. It essentially kicks down the road the need for our physicians to understand and utilize ICD-10. We have a large owned multispecialty practice and our stance is that correct ICD-10 codes will be the standard starting Oct. 1, 2015. What we don’t know is what we will be getting from community physicians in terms of outpatient orders.
At this time, we are planning for the worst and putting in place processes for dealing with prescriptions that have incorrect or incomplete codes. The plans include: How do we ensure that there are no long lines and wait times? Who will work with the patient? Who will help them call their physicians to get the right codes? How do we ensure customer satisfaction and service recovery? How do we make sure patients get the services they need in a timely fashion?
Given how far we have come, this is just another hurdle in the race we have been running. All we can do is finish the race in 57 days and ensure that we keep our eye on the prize — patient safety and satisfaction.
Linda Reed, R.N., is vice president, behavioral and integrative medicine, and chief information officer at Atlantic Health, a five-hospital health system based in Morristown, N.J.