ICD-10 and Non-covered Entities

While preparing for ICD-10-CM transition, non-HIPAA entities need to be considered. What about non-covered entities? What are they doing for ICD-10-CM transition? What do they have to do for ICD-10-CM transition? What is a non-covered entity?

The Final Rule requires HIPAA covered entities to adopt the ICD-10-CM and ICD-10-PCS code sets. Non-covered entities do not have to transition to Version 5010 and ICD-10, although it is recommended that they do. Non-covered entities include: workers’ compensation programs, life insurance companies, automobile insurance companies, and disability insurance programs that submit non-covered transactions (e.g., paper claims, quality reporting, and patient assessment data sets).

According to CMS’ July 2011 “The ICD-10 Transition: Focus on Non–Covered Entities,” the benefits for non-covered entities to transition to ICD-10 include:

  • Expanded detail in injury codes, which will help automobile insurance and workers’ compensation programs.
  • ICD-9-CM codes will no longer be maintained once ICD-10 has been implemented. The ICD-9-CM code set will become less useful and resources will be continually harder to obtain.
  • Not adapting to ICD-10 coding could lead to undue hardship for non-covered entities’ providers.

So, what can an office, clinic, or facility do to prepare for this potential curve ball? Its homework. If you currently transmit claims to non-covered entities, it is a good idea to start assessing how many of them you are actually transmitting to. Contact the agencies you send the most claims to and ask what their plans are for ICD-10. Do they plan on converting along with the rest of the country? Are they going to hold out for a year? Two? Are they not even currently planning on converting? For agencies that you do not send a lot of claims to, assess if it is worth it to continue contracting with them if they do not transition to ICD-10 in 2013. Gather all the information available from these entities, evaluate it, and make decisions that make sense for your practice.

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