ICD-10 and the Compliance Office – What Can We Do To Get Started?

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  • December 30, 2009
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Jillian Harrington,
ICD-10 Curriculum Team
American Academy of Professional Coders
One of the questions I receive most often when out and speaking with people in the compliance community about ICD-10 is “What can we do to get started?”.  Compliance professionals are in an interesting situation, as they are not typically the main starting point for operational issues such as these.  However, an early start to becoming compliant with the ICD-10 code sets, either as a provider or a payer is obviously of great importance to all compliance staff.
There are actually a few different ways compliance staff members can get involved in preparation for the ICD-10 code set transition.  First, get involved with the planning or steering committees in your organization.  Find out who is the point person for the ICD-10 transition, and make it known to that person that you’re interested in being involved.  Most compliance professionals will be in an excellent position to serve as a subject matter expert with regard to the regulations, but depending on the make-up of your compliance office, you might also be able to speak for the quality of documentation found in the medical records for your organization, in comparison to the higher level of documentation needed to support the ICD-10 code set.  Also, a large part of preparation for ICD-10 transition in the provider setting is auditing of documentation to compare current code assignment and future code assignment.  Compliance auditors are obviously well qualified to perform this task.  Finally, compliance staffs are also typically well versed in providing practitioner and other staff education, which is something that will obviously be greatly needed in the transition process as it moves forward.
A second way to get involved in the preparation is to learn all that you can about the ICD-10 code set.  Visit some of the many websites providing accurate information about ICD-10, such as the AAPC ICD-10 website (http://www.aapc.com/ICD-10/), the CMS ICD-10 website (http://www.cms.hhs.gov/ICD10/), and the NCHS ICD-10 website (http://www.cdc.gov/nchs/icd/icd10cm.htm).  Listen in on the archived webinars on the AAPC website to learn some basic information about the implementation process, and also look to the AAPC local chapter in your area, as they may be offering some ICD-10 programming in the future as well.  By following the CMS website link above, and clicking on the ‘Educational Resources’ link on the left side of the page, you’ll also have access to the CMS training resources they’ve made available to the health care community to assist us in our preparation for transition.  Learn all that you can about the ICD-10 code set and ICD-10 implementation process and you’ll make yourself a vitally important part of your ICD-10 planning, steering and implementation team(s).
Once the transition to ICD-10 has occurred, the compliance office will play an important role in maintaining compliance, and also improving documentation.  Ongoing medical record coding and documentation audits will be key to ICD-10 compliance into the future.  Also, provider education on documentation improvement, based on what is found upon audit will also be very important.  The higher level of documentation required to support diagnosis codes in the ICD-10 code set may create medical necessity denials that organizations haven’t faced in the past.  By catching these types of issues early on and providing education to providers, compliance staff can serve as an important piece of the ICD-10 transition team, from both a compliance and financial perspective.


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