ED Coding and Reimbursement Alert

Plus: CMS has proposed freezing the ICD-9 code set after next year.

If you were hoping that the Oct. 1, 2013 ICD-10 implementation date wasn't set in stone, you are out of luck. That's the word from CMS during a June 15 CMS Open Door Forum entitled "ICD-10 Implementation in a 5010 Environment."

"There will be no delays on this implementation period, and no grace period," said Pat Brooks, RHIA, with CMS's Hospital and Ambulatory Policy Group, during the call. "A number of you have contacted us about rumors you've heard about postponement of that date or changes to that date, but I can assure you that that is a firm implementation date," she stressed. Brooks indicated that the rumor about a potential delay in the implementation date continues to persist throughout the physician community, and recommended that practice managers alert their physicians to the fact that the rumor is untrue.

The Oct. 1, 2013 date will be in effect for both inpatient and outpatient services. Keep in mind that the ICD-10 implementation will have no impact on CPT and HCPCS coding, Brooks said. You will still continue to bill your CPT and HCPCS procedure codes as before.

You'll Find Nearly 55,000 Additional Codes

Currently, CMS publishes about 14,000 ICD-9 codes, but there are over 69,000 ICD-10 codes. The additional codes will allow you to provide greater detail in describing diagnoses and procedures, Brooks said.

If you're wondering which specific codes ICD-10 includes for your specialty, you can check out the entire 2010 ICD-10 code set, which CMS has posted on its Web site: www.cms.gov/icd10. "Later this year, we'll be posting the 2011 update," Brooks said during the call.

In addition, you can review general equivalence mappings (GEMs) if you'd like information on how to convert data from ICD-9 to ICD-10 or vice-versa. The GEMs can be helpful if you're converting lists, systems, or applications from one system to another.

"Some people refer to these as crosswalks, others call them mapping, but they're basically forward and backward mapping between the coding systems," Brooks said. However, "the GEMs are not a substitute for learning how to code ICD-10, and, frankly, for some of you who have small projects with just a few codes, you may not want to bother with the GEMs, it's probably just quicker to pick up an ICD-10 code book and use that rather than the GEMs," she noted.

o Vendors, payers, and coding educators have asked CMS to freeze the current diagnosis code set to help make ICD-10 transition planning simpler. CMS therefore created a proposal under which it would update the ICD-9 code set one last time on Oct. 1, 2011, after which no ICD-9 codes will be added to the set except for those updates required for new technologies and diseases. Regular updates to ICD-10 would begin on Oct.

1, 2014 under the proposal.

"We plan to make a final decision on any code freeze and announce it at the Sept. 15 to Sept. 16 2010 ICD-9 Coordination and Maintenance Committee meeting," Brooks said. New 5010 Form Will be Required in 2012 In preparation for the use of ICD-10, CMS has introduced its new HIPAA 5010 Version D.0 form, which will be required to use by all HIPAA-covered entities (i.e., providers, health plans, clearinghouses, and their business associates, including billing agents) as of Jan. 1, 2012, said Christine Stahlecker of CMS's Office of Information Services, during the Open Door call.

Although CMS has noted the fact that the new 5010 form is a prerequisite for ICD-10 implementation (due to its increased field sizes and increased number of diagnosis codes allowed on a claim), the agency also stressed the fact that the new 5010 does not do the ICD-10 prep work for you.

"With our 5010 project, we are not adding any processing of the ICD-10 code values, and we are not including any crosswalk from ICD-9 to ICD-10," Stahlecker said. "So although the 5010 form permits both the ICD-9 and ICD-10 code values, only ICD-9 will continue to be processed up until the ICD-10 project permits ICD-10 codes to come in."

Timeline: Keep in mind that CMS will begin accepting 5010 forms effective Jan. 1, 2011, and use of the form will be required as of Jan. 1, 2012. The ICD-10 codes will take effect on Oct. 1, 2013.

If you're not ready to submit the 5010 form by Jan. 1, 2012, "you will no longer be able to submit electronic transactions" to Medicare, Stahlecker said. "Providers that are submitting paper claim forms today should not experience a change in that paper claim form for 5010 or the ICD-10 projects. Our understanding is at this time, those paper claim forms can already accommodate the additional length of the diagnosis codes," Stahlecker said.

CMS will present a follow-up conference call regarding ICD- 10 on Sept. 13, said Hazeline Roulac, a health insurance specialist with CMS. For details on upcoming calls, visit www.cms.gov/icd10.