EHR and Health IT Consulting
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EHR and Health IT Consulting
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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Is your medical practice ready for dual coding?

Is your medical practice ready for dual coding? | EHR and Health IT Consulting |

Although medical practices cannot submit medical claims with ICD-10 codes until Oct. 1, there are a few good reasons to start using them sooner.

Those reasons support dual coding — when healthcare organizations assign ICD-10 and ICD-9 codes simultaneously to medical records.

The advantages include:

  • Medical coders can practice their ICD-10 knowledge
  • Clinical documentation deficiencies are exposed
  • Extensive internal and external testing can be done

This won't be cheap. Systems need to be designed for dual coding. And no matter what your vendor promises, dual coding is extra work. That means there will be a productivity loss. Maybe computer assisted coding (CAC) will help. Costs would be associated with:

  • Added time
  • Maintaining data collection
  • Analyzing data

Medical practices likely will need to assign extra coding resources. Extra medical coders can be hired to cover the dual coders. Healthcare providers need to do a cost-benefit analysis to determine if it's better to hire personnel or accept longer reimbursement cycles.

To get dual coding started, the Centers for Medicare and Medicaid Services (CMS) recommends answering the following questions:

  • Can the practice management system (PMS) or electronic health record (EHR) can capture ICD-9 codes and ICD-10 codes in the same patient encounter?
  • How much dual coding will be done?
    • How often?
    • How many encounters will be processed?
    • Are all diagnoses or just the top X percent of diagnoses are represented?
  • Will the ICD-10 codes be captured in the PMS or EHR system or on paper?

Before dual coding can start, a medical practice should:

  • Upgrade systems so they are ICD-10 compliant.
  • Make sure clinical documentation can support ICD-10 coding.
  • Start ICD-10 training and education.
  • Test with healthcare vendors or payers.

Then start practicing ICD-10 coding on real cases in the medical practice. Chances are that all this time and money will be investments that payoff after Oct. 1.

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No ICD-10 Delay Included in Latest Congressional Spending Bill |

No ICD-10 Delay Included in Latest Congressional Spending Bill | | EHR and Health IT Consulting |
Lawmakers have not included an ICD-10 delay in the 2015 Congressional spending omnibus.

Rumors of another ICD-10 delay appear to be greatly exaggerated – this time, at least.  Despite calls from the Medical Society of New York to include an additional two-year delay of ICD-10 in the $1 trillion omnibus spending bill that funds most Congressional activities through the majority of 2015, the legislation did not include an additional push-back of the health information management schema before lawmakers agreed on the final form of the bill.

While the legislation is certainly not the only opportunity for Congress to scupper the new code set, it does give providers some confidence going into the holidays that ICD-10 will continue as planned on October 1, 2015.  Uncertainty about the actual implementation date has left many healthcare organizations wondering about the point of spending time, effort, and money on upgrade systems and processes to be compliant with ICD-10 requirements.  Advocates of postponing ICD-10, or scrapping it all together, have tried to feed on these worries to build momentum for their cause.

“The onerous penalties tied to these mandates add to the hysteria that is running through physicians’ offices and is generating many early retirements,” states the Medical Society of New York in a letter addressed to Rep. John Boehner in November. “If every entity in the complex medical payment pyramid does not function perfectly on October 1, 2015 then physicians’ income goes to zero which is a steep price to pay for a new imperfect coding system.”

The American Medical Association, another staunch advocate of abandoning the ICD-10 mandate, has also raised arguments about the cost of implementation and the burden on physicians to comply with the new codes in addition to several other major healthcare reform initiatives.  Boasting that the AMA has held off ICD-10 for more than ten years, Dr. Robert Wah recently made a speech decrying ICD-10’s less common codes and urging providers to join his organization in opposition to the code set.

However, after the most recent delay from 2014 to 2015 shocked ICD-10 proponents and threw the industry into turmoil, many organizations just want to get it over with.  In another letter to Rep. Boehner, this time from a coalition of hospital and health systems, ICD-10 advocates note that repeated delays have been highly disruptive, costly, and frustrating for the healthcare community.

“The delay added billions of dollars in extra costs,” state the American Hospital Association, Premier Healthcare Alliance, and a number of health systems.  “Many of our members had to quickly reconfigure systems and processes that were prepared to use ICD-10 back to ICD-9.  A further delay would only add additional costs as existing investments would be further wasted and future costs would grow.

Wrangling over the true financial impact of implementation has added to the confusion among healthcare providers, who have been chronically lagging behind recommended timelines and guidelines for testing, education, and upgrades.  “The lack of progress by providers, in particular smaller ones, remains a cause for concern as we move toward the compliance deadline,” said Jim Daley, WEDI chairman and ICD-10 Workgroup co-chair in a September letter to HHS Secretary Sylvia Burwell. “Delaying compliance efforts reduces the time available for adequate testing, increasing the chances of unanticipated impacts to production. We urge the industry to accelerate implementation efforts in order to avoid disruption on Oct. 1, 2015.”

Lawmakers have until Thursday to vote through the omnibus spending bill if they are to avoid another paralyzing governmental shutdown.  While the most recent ICD-10 delay was slipped into the SGR reform bill without much notice, it does not appear that the divisive code set will make a cameo in this latest bipartisan agreement.

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Congress Strongly Leaning towards 2015 ICD-10 Implementation

Congress Strongly Leaning towards 2015 ICD-10 Implementation | EHR and Health IT Consulting |

October 1, 2015 looks like it may be the final ICD-10 implementation date after members of Congress and representatives from the healthcare industry voiced their support for the new code set during a hearing of the House of Representatives’ Energy and Commerce Committee’s Subcommittee on Health.  Despite lingering opposition from some stakeholders worried that small practices will fold under the financial burden of adopting the new codes, the majority opinion has turned in favor of refusing any more delays.

“The last minute delays do nothing to relieve the pressure for the small practice that struggles under this administrative burden,” said Dr. Michael C. Burgess (R-TX), an obstetrician and gynecologist. “It does put the health systems and insurers in a difficult position as well.  In fact, it punishes those who have done exactly what Congress has requested.”

“Each delay has been costly to the healthcare system,” added Rep. Gene Green (D-TX).  “The ICD-10 transition is an important part of bringing our healthcare system into the 21st century.”

The panelists testifying during the hearing included representatives from medical groups, vendors, payers, and AHIMA, the majority of whom also expressed enthusiasm for keeping the ICD-10 implementation date as it is.

“It is critically important for the health care system to move forward with this new system under the current timetable,” said Carmella Bocchino, Executive Vice President at America’s Health Insurance Plans (AHIP) during her testimony. “Doing so will establish a strong foundation for allowing health plans and health care providers to identify and report conditions and medical treatments in more specific ways, ultimately leading to more effective measurements of quality and health outcomes.”

Bocchino noted that the nation’s major private payers have poured significant time and resources into preparing themselves and the industry for the switch.  Aetna, Cigna, and Humana have conducted extensive ICD-10 testing over the past two years, she said, while many of the Blue Cross Blue Shield organizations have provided educational resources and readiness checks for providers throughout the preparation period.

“We need it.  We’re ready,” stated Richard F. Averill, MS, Director of Public Policy for 3M Health Information Systems.  “Congress rightly wants to move the health care system to focus more on value over volume. I’m here to tell you – you can’t do it with ICD-9. You need ICD-10. It is simply time to have our diagnosis and procedure coding systems reflect modern medicine. ICD-10 is a long overdue replacement for the outdated ICD-9-CM system for reporting diagnosis and procedure information. If we are to rate hospitals and physicians based on their outcomes, we need ICD-10. If we are to better assess what procedures, technologies, or approaches best aid improving patient care, we need ICD-10.”

The hearing comes on the heels of a Government Accountability Office report affirming that CMS has properly prepared its Medicaid systems to handle ICD-10 claims.  However, significant skepticism remains about the ability of CMS to handle such a massive undertaking in light of its history with major IT projects.

“All roads eventually lead to CMS,” said Dr. Burgess.  “And if you will pardon me, that does appear to be a weak link in the chain.  From to the Sunshine Act reporting website…when CMS flips the switch, something breaks.  Any time they flip a switch that involves the processing of data, their systems fail.”

“So it begs the question: is flipping a switch on October 1 the right move?” Burgess asked.  “And if it is, what is the contingency plan for any problems that may develop?  Today I am anxious to discuss not just the implementation plan, but I’d also like to talk about the contingencies if everything doesn’t go exactly as planned.”

Contingency planning has largely been left up to individual providers, which are encouraged to take steps such as keeping cash on hand to mitigate the impact of delayed or denied claims.  CMS itself has said little on the matter, and is currently focused on conducting end-to-end testing with a select group of sample providers throughout the spring.  Recent research has suggested that the financial impact for healthcare organizations may be less than predicted, allowing some breathing room for revenue cycles after go-live.

Overall, the hearing acknowledged that ICD-10 is a necessity for the healthcare industry as it transitions to value-based care and team-based population health management, both of which rely heavily on the improved specificity and more granular data of ICD-10.

“It’s been on the agenda for a long time,” said Rep. Chris Collins (R-NY).  “This isn’t something that should be new to anyone.  I certainly have a lot of physician friends and I understand there is a cost to implementing anything new.  I’m also a data guy, and I know that with data, while it may not be a positive for that patient today, at some point in time being able to deep dive into data is important.  Especially with healthcare costs going up in this country as they are, someone will be able to use that data.  I would see data collection as a very major part of why we’re doing this.”

Barring the appearance of another behind-the-scenes shocker like the surprise delay in 2014, it appears that ICD-10 implementation is building enough momentum to barrel through continued objections from the American Medical Association and other groups that remain worried about the costs and impacts of the codes.  If the October 1, 2015 deadline sticks this time, providers that may have been banking on an additional extension will need to squeeze a number of preparation activities into a quickly shrinking window of just under eight months.

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