Inpatient Facility Coding & Compliance Alert

Question: Is there any policy for processing split claims for certain institutional encounters that span the ICD-10 implementation date?

Texas Subscriber

Answer: CMS has published information regarding the processing of claims that span the ICD-10 implementation date, that is, when ICD-9 codes are effective for that portion of the services rendered on Sept. 30, 2015, and earlier, plus when ICD-10 codes are effective for that portion of the services rendered on Oct. 1, 2015, and later.

As far as inpatient and Part B hospital services split claims are concerned, we use bill type 12X. CMS will require providers to split the claim so all ICD-9 codes remain on one claim with dates of service (DOS) through 9/30/2015 and all ICD-10 codes placed on the other claim with DOS beginning 10/1/2015 and later.

Creating multiple/interim claims on a single encounter is not a new concept, and CMS says that these instructions will apply to relatively few claims per institution because only claims that span this single implementation date (Oct. 1, 2015) will be impacted.

Moreover, when you split claims for an encounter spanning the ICD-10 implementation date, remember to maintain all charges with the same Line Item Date of Service (LIDOS) on the correct corresponding claim for the encounter.

Remember: Single item services whose time-frame cross over midnight on Sept. 30, 2015 (e.g., emergency room visits and observation), are not split into two separate charges, rather the single item service should be placed in the claim based upon the LIDOS:

1) For ER encounters the LIDOS is the date the patient enters the ER; and

2) For observation encounters it is the date that observation care begins.

Please refer to the “Medicare Claims Processing Manual”, Chapter 4 (Part B Hospital Including Inpatient Hospital Part B and OPPS), Sections 180.6 Emergency Room (ER) Services That Span Multiple Service Dates and 290.2.2 (Reporting hours of observation for observation services), respectively, for more information about Emergency Department and observation claims. Reach this manual at http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c04.pdf on the CMS website.

You may seek further guidance for such split claims from the MLN article: http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1408.pdf