Anesthesia Coding Alert

Part of your 2012 plan should include focusing on your most common codes.

Despite recent rumors, CMS has no intention of delaying the implementation of ICD-10 beyond the Oct. 1, 2013 date, according to CMS's Kyle Miller. That means every physician group should be taking steps toward the transition. Keep moving in the right direction with three top FAQs based on CMS representative comments in recent CMS ICD-10 teleconferences.

Know Penalties for Nonparticipation

Question: What are the penalties for entities that are covered under HIPAA who choose not to use ICD-10 codes as of Oct. 1, 2013?

Answer: Your claims will be denied -- and you technically could face fines since using the ICD-10 codes falls under the HIPAA transaction code set regulations, CMS reps noted.

"From a practical standpoint, as of service dates of Oct. 1, 2013, if you don't use ICD-10 codes, most likely your claims will be returned and will be asked to transition to ICD-10," said CMS's Denise Buenning, MsM.

"The penalties are the same penalties that any HIPAA entity would be subject to," Buenning added. "I think most of you are familiar with the ongoing HIPAA transaction code set penalty that calls for a maximum of $25,000 per covered entity per year, but the HITECH legislation of last year actually upped those transaction and code set penalties, and they can be as much as $1.5 million per entity per year. So obviously it behooves everybody -- Medicare and Medicaid inclusive -- to make sure we are compliant with these ICD-10 codes by the Oct. 1, 2013 date."

LCD Updates Could Come Later

Question: The Medicare local coverage decisions (LCDs) currently list the payable ICD-9 codes that correspond to all Medicare-payable procedures. Will contractors issue updated LCDs to the public prior to the Oct. 1, 2013 implementation date to show the payable ICD-10 codes for the procedures?

Answer: The answer to that isn't yet crystal clear. "The LCDs will be translated because they will need to be translated, [but] as it relates to having them available to the public prior to the implementation date, that I'm not sure of, because we are working fast and furious on all of our ICD-10 implementation efforts," said CMS's Lisa Eggleston, RN, MS.

Whittle Down Your Code List

Question: What can our practice do to get ready for the ICD-10 conversion?

Answer: One thing you won't need to do is remember a bunch of new codes. "In fact, most practitioners probably don't know many ICD-9 codes by heart, so they won't be expected to memorize ICD-10 codes either," said Daniel Duvall, MD, medical officer with CMS's Hospital and Ambulatory Policy Group.

Strategy: Use your list of the top diagnoses that your practice sees to find the corresponding ICD-10 codes, and "you've got your cheat sheet," Duvall said. Then, ensure that your coders are trained, that your claims are form 5010 compliant, and that your claim submission system supplier is ICD-10-ready. In addition, if you have an electronic medical record or you plan to get one, make sure it can handle ICD-10. "If you're starting to bring in an EMR, you want to convert to ICD-10 first, not bring one in under ICD-9 and then convert," Duvall added.