Pathology/Lab Coding Alert

Make Sure You're Ready When CMS Scraps 90-Day Grace Period

Update your code sets to prevent denials

You will no longer have a 90-day grace period to implement new ICD-9 and HCPCS codes, thanks to HIPAA requirements, according to CMS transmittals Nos. 89 and 95. But the change shouldn't cause you many problems, coding experts say.

The grace period allowed providers "to ascertain the new codes and learn about the discontinued codes," CMS says. But HIPAA's "transaction and code set rule" mandates that physicians and practices report codes that are valid at the time the physician rendered the service. Therefore, you will no longer have a 90-day grace period for billing discontinued ICD-9 codes starting Oct. 1, 2004. The grace-period ruling becomes effective for HCPCS Level I and Level II on Jan. 1, 2005.

Example: The new ICD-9 changes that are effective Oct. 1, 2004, delete code 066.4 (West Nile fever), which included the descriptors West Nile encephalitis, West Nile encephalomyelitis, and West Nile virus. ICD-9 adds four more specific, five-digit codes in its place, one of which is 066.41 (West Nile fever with encephalitis).

Under the old grace period, most Medicare carriers would have accepted deleted code 066.4 for a patient with West Nile encephalitis until Dec. 31, 2004. Without the grace period, however, you should report 066.41 on Oct. 1, or your Medicare payer should deny your claim.

What to do: You shouldn't encounter many coding difficulties or denials without a grace period as long as you update your code sets by the ICD-9 and HCPCS deadlines, says Melanie Witt, RN, CPC, MA, an independent coding consultant in Fredericksburg, Va. The Federal Register usually publishes new codes well in advance of their release, so you should have enough time to make the changes, she adds.

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