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Technical Doctor's insights and information collated from various sources on EHR selection, EHR implementation, EMR relevance for providers and decision makers
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The SGR Repeal Bill Looks to be ICD-10-Free; That’s a Great Thing

The SGR Repeal Bill Looks to be ICD-10-Free; That’s a Great Thing | EHR and Health IT Consulting | Scoop.it

It’s been a very busy last few weeks in health IT. While everyone is doing their annual prep for the upcoming Healthcare Information and Management Systems Society (HIMSS) conference, held this year in Chicago in two weeks, a few major policy developments have hit the industry and have the potential to bring massive change to the healthcare landscape.


One of these developments is the proposed legislation to repeal Medicare’s Sustainable Growth Rate Formula (SGR) for physician payment, and institute a 0.5-percent payment update for the next five years for physicians, under Medicare. This bill has been passed in the House of Representatives, and is expected to pass in the Senate in two weeks, according to HCI sources with Congressional ties. While it was reported that there was no language in the bill that would further push back the transition to ICD-10—currently set for Oct.1, 2015—it would be foolish to ever count such a thing out, after past developments have proved that no matter what you might think, there could be high-level people behind another delay.


However, in his Washington Debrief this week, Jeff Smith, vice president of public policy at the College of Healthcare Information Management Executives (CHIME) noted that, “Despite the introduction of an amendment to delay the new coding set to 2016 by freshman Representative Gary Palmer (R-MS-04) it was not allowed to be included in the bill by House leadership.” Indeed, in January, Palmer was part of a group of congressional members who sent a letter to Alabama's Congressional Delegation urging to delay implementation of ICD-10 until October 2017, if not get rid of it completely until ICD-11 comes around.


The letter stated various reasons why a delay was necessary, mainly the increased granularity with codes and the extra cost for healthcare organizations.  “While spending more time with patients is what patients and physicians want, under ICD-10 we will instead spend more hours in front of a computer screen scanning 68,000 medical codes looking for the right one,” the letter states. It continues, “The transition to ICD-10 is expected to cost more than $1.64 billion over 15 years, with more than 40 percent of that expense coming from the cost of upgrading information technology systems for different participants including the government, insurance companies, physicians and hospitals.”

While I won’t argue the specific points of cost and physician training, I will disagree with Palmer on his overall take. Simply put, the industry cannot go through the burden of another delay; its effects would be rippling. There has been a great deal of money spent on ICD-10 already. How do vendors, hospitals, physician groups, and others recoup the loss of money spent getting ready if yet another delay occurs? A delay until 2017 is just the wrong move—as our Senior Editor Gabe Perna reported last month, on an ICD-10 hearing held by the House of Representatives’ Energy and Commerce Committee’s Subcommittee on Health, one of the panel members said it’s time to move forward or pull the plug. And to be honest, it’s too late to pull the plug. There has been too much invested already.


Also, regarding the boost in medical codes, while naysayers point to the increased granularity involved with that, it’s likely that providers won’t have to worry about all of them. This is according to Fletcher Lance, managing director and national healthcare leader of the Nashville, Tenn.-based North Highland, a global consulting firm, who recently told me that the firm’s Codes That Matter approach prioritizes ICD-10 implementation activities by identifying those codes that are tied to the largest revenue streams at a given healthcare organization.

To find the codes that matter, North Highland assesses multiple factors that contribute to the complexity and potential impact of the ICD-10 transition on physician and clinician productivity and organization revenues. As such, Lance says, “We find that, of the 68,000 codes that you’ll see in the hospital setting, maybe 300-500 codes matter, and often even less than that,” he says. “Not all codes are created equal; we can and have predicted which ones matter.”


This is not to say that the extra training and education isn’t necessary, but that it might not be as drastic as people such as Palmer are saying. It’s also not to say that ICD-10 doesn’t come without concerns. Earlier this month, nearly 100 physician groups representing state and specialty medical societies have written a letter to the Centers for Medicare & Medicaid Services (CMS) regarding said concerns, specifically about a lack of industry-wide, thorough end-to-end testing. Certainly, ICD-10 is not without problems or challenges, but another delay or pulling the plug is not the answer at this point of time.

The time has come to finally close the door on any talk of more delays, and see ICD-10 through to its completion. The transition needs to be done both correctly and on time, or the same cycle of ambiguity will only continue. At this point it doesn’t even matter what side you are on when it comes to the transition—after all the work that has already been done, it’s time to move forward. Thankfully, it looks like the lack of an amendment in the SGR repeal legislation will allow us to do just that.


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CMS Extends Hospital 2014 Meaningful Use Reporting Deadline | EHRintelligence.com

CMS Extends Hospital 2014 Meaningful Use Reporting Deadline | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it

While this week marks the end of one and beginning of another year, those in the healthcare industry should take note of all that transpired in the previous year to avoid similar setbacks in 2015. This is especially true for matters scheduled to have been addressed over the last 12 months.

ICD-10 delays, meaningful use changes, health IT vendor competition, and EHR implementation gaffes. Based on the interest of our readers, those were the most popular topics of 2014 on EHRIntelligence.com.

ICD-10 transition delay one more year

More than any other topic on our news site, ICD-10 garners the greatest amount of our readership’s attention and given its high stakes, it makes sense. This past October was supposed to usher in a new era of clinical coding — the move from ICD-9 to ICD-10 — and put the United States on par with other leading nations in terms of healthcare documentation.

The Congressional debate over the sustainable growth rate (SGR), however, swiftly dashed those visions. Close to one week after expectations began to build that Congress would vote on an SGR patch that included a one-year ICD-10 compliance delay, the Senate voted in favor of the bill. While the rest of the nation took this as business as usual on the Hill, the healthcare industry scrambled to put new plans together for postponing their 2014 ICD-10 implementation activities.

What the delay meant to providers depended on where they practices. Larger healthcare organizations reported high levels of ICD-10 readiness while some smaller physician groups and practices were completely unsure where they stood. No matter their view of the most recent ICD-10 delay, most are committed to removing ICD-10 implementation pain points to be ICD-10 ready by Oct. 1, 2015.

The bending but not breaking of meaningful use

This past year began with eligible professionals and hospitals working to achieve Stage 2 Meaningful Use, but that is hard to do when certified EHR technology is unavailable.

Early hints of changes to meaningful use reporting in 2014 emerged as early as February when the Centers for Medicare & Medicaid Services (CMS) introduce a new meaningful use hardship exception dealing with a lack of available CEHRT.

In September, the federal agency finalized a rule intended to give providers greater flexibility in meeting meaningful use requirements in 2014 — known as the flexibility rule. However, this did not turn out to be CMS’s final move.

The flexibility rule was followed by the reopening of the meaningful use hardship exception application submission period for both EPs and EHs and the extension of the 2014 meaningful use attestation period for EHs and critical access hospitals through the end of the year.

Despite their intentions, neither has put to rest repeated calls for 2015 meaningful use reporting requirement changes by industry stakeholders.

Heading to a showdown

Prognosticators in health information technology (IT) have foreseen consolidation in the marketplace over the next few years. But it is unlikely that they saw things playing out as they did in 2014.

Cerner’s acquisition of Siemens Health Siemens over the summer is an example of how quickly and dramatically the market can change. Most viewed the maneuver as a power play by the Kansas City-based health IT company to contend with Epic Systems and its market share among health systems and hospitals.

While the growth of both Cerner and Epic continues to loom large over the industry, they still have to contend with numerous other players in the ambulatory care space, especially given Epic’s recent loss to athenahealth as the top overall software vendor over the past year.

Expect more to come.

Squeaky wheel gets the grease

When EHR implementations go well, those involved in the process are more than willing to share details of their experiences. When they don’t, it is like pulling teeth.

Poorly managed EHR implementations can prove costly. The University of Arizona Health Network saw red of a different variety as a result of its Epic EHR adoption. Whidbey General Hospital felt the financial effects of a software glitch in its MEDITECH EHR that crippled its billing system and left it short on cash. Meanwhile, a Cerner EHR implementation gone awry led to the dismissal of Athens Regional Medical Center’s CEO.

If 2014 was a busy year, then 2015 is only likely to be busier. Stay with us as we continue our coverage of meaningful use, EHR and ICD-10 implementation, and anything else health IT-related that comes our way.



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ICD-10 Acknowledgement Testing Checklist for Providers

ICD-10 Acknowledgement Testing Checklist for Providers | EHR and Health IT Consulting | Scoop.it

While ICD-10 acknowledgment testing is available any day of the year up until October 1, 2015, CMS is taking the first week in March to host another dedicated opportunity for providers.  The testing weeks serve as way to gather data about the way providers send their sample ICD-10 claims to Medicare and allow providers to ensure that their claims can be accepted by the adjudication system without any technical glitches.

Those organizations that have not participated in previous testing weeks are encouraged to join in during the next chance on March 2 through 6, or the final scheduled occasion at the beginning of June.

In order to successfully submit claims for ICD-10 acknowledgement testing, direct-submit healthcare organizations, including providers and clearinghouses, will need to keep the following questions, tips and, requirements in mind.

What is ICD-10 acknowledgement testing?

Acknowledgement testing is the most basic form of assurance that a claim can be accepted by a Medicare Administrative Contractor (MAC) for later adjudication.  It should not be confused with end-to-end testing, in which a claim is processed through all Medicare system edits in order to produce electronic remittance advice (ERA).  Acknowledgement testing simply provides a yes or no answer to the question of whether or not the sample claim can be accepted.

Providers are encouraged to use ICD-10 acknowledgement testing as a basic way to ensure that they are on the right track with their ICD-10 preparation.

How do I participate?

Information about acknowledgement testing will be provided on your local MAC website or by your clearinghouse.  Any provider that submits electronic Medicare fee-for-service claims is eligible for participation.  There is no registration required.  For more information on eligibility, click here.

ICD-10 acknowledgement testing does not test initial connectivity to the MAC system, nor does it ensure that your internal systems are capable of producing, accepting, storing, or transmitting codes.  Internal preparations for the generation and transmission of ICD-10 codes should already be completed before MAC testing.

How do I prepare my sample claims for submission?

Ensure that you have enough claims coded in ICD-10 to represent your typical submissions spectrum.  CMS reminds providers that claims must have the “T” in the ISA15 field to indicate the file is a test file.  Use a valid submitter ID, national provider identifier (NPI), and Provider Transaction Access Numbers (PTAN) combinations.  Claims that contain invalid identifiers will be rejected.

Be sure that the claims do not include future dates of service.  All claims must be dated before March 1, 2015 in order to be processed. Claims must also have an ICD-10 companion qualifier code or they will be rejected.

Providers may engage in “negative testing” by submitting purposely erroneous claims in order to confirm that the MACs will catch defects or incorrect information.

What information will I receive from my MAC?

Test claims will be assigned a 277CA or 999 acknowledgement as confirmation that the claim was accepted or rejected by the system.  The test will not confirm that the claim would be paid under ICD-10, nor will testers receive any remittance advice.  The MACs and the Durable Medical Equipment (DME) MAC Common Electronic Data Interchange (CEDI) will have extra staff available to take calls from providers who have questions about the process or their results.

Providers will need to engage in full end-to-end testing with their payers if they wish to receive information about their coding accuracy or payment rates.  While CMS has scheduled end-to-end testing for April 2015, participating providers have already been selected.  Providers are still encouraged to engage in end-to-end testing with their private payers as soon as possible.

What do I do next?

During prior acknowledgement testing, CMS has released basic data on acceptance rates several weeks after the dedicated testing period.  But providers participating in the opportunity do not need to wait until then to take action based on their own results.  With a mere seven months until October 1, 2015, organizations that experienced unexpected denials from acknowledgement testing should work with their ICD-10 preparation teams or consultants to resolve internal or coding errors quickly.

Healthcare organizations should also make sure that they are coordinating with their major payers to conduct additional, more robust testing of ICD-10 claims.  Providers should continue to utilize clinical documentation improvement programs, revenue cycle contingency planning, and coder training and education during the last few months of preparation in order to combat potential negative impacts from the new codes.


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