Home Health & Hospice Week

Can you pull yourself into compliance with the 155,000-code system in time for CMS’s proposed deadline?

If the feds forge ahead with their proposed timeline for ICD-10 implementation, it will be home care providers who pay a steep price.

In an August proposed rule, the Centers for Medicare & Medicaid Services floated a 2011 implementation date for the new ICD-10 coding system that will replace the current ICD-9 format (see Eli’s HCW, Vol. XVII, No. 37, p. 294). The ICD-10 system will increase the number of diagnosis codes from the current 17,000 to a staggering 155,000.

The new ICD-10 system will greatly im-prove reporting of health conditions for public health, payment, and quality purposes, acknowledged the National Association for Home Care & Hospice says in its comments on the rule. NAHC supports adoption of ICD-10-CM in general.

But NAHC urges CMS to ensure adequate provider education beginning now and recommends that the ICD-10 compliance date be set for no earlier than Oct. 1, 2012.

NAHC’s recommendation echoes that of other provider groups, like the Medical Group Management Association, which calls the implementation schedule unworkable.

"The costs associated with implementing ICD-10 in such a short timeframe are markedly higher than what CMS has estimated," MGMA says, based on a study it commissioned conducted by Nachimson Advisors.

Watch out: Home care represented only 0.06 percent of the impact studies that predicted transition costs, says Trish Twombly, director of coding with Foundation Management Services in Denton, Texas. Although the rule states "the adoption of the new codes will likely touch every provider who submits diagnostic codes and every payer that processes health care claims," it goes on to say, "without more details we cannot conclusively determine the extent of the system conversion costs of long term care facilities, home care providers, and other non-hospital organizations. It may be that the system conversion costs for these types of health providers are underrepresented."

Reading this type language in the proposed rule "deeply troubles me," Twombly tells Eli. "Home care will have tremendous costs in staff education, software conversions, and lost productivity, to name just a few areas, and yet our industry was not included in the conversion cost studies."

More than just codes: The newest version of OASIS-C (see related articles, p. 348) includes the requisite number of spaces for the sometimes seven-digit codes required by ICD-10-CM, so obviously Medicare is preparing for the change, says Lisa Selman-Holman of Selman-Holman & As-sociates in Denton, Texas. The conversion to ICD-10-CM in home health means form conversions, software conversions, and a whole new update to the prospective payment system since the existing case mix codes will no longer exist, she says.

Hear The Other Side

But the American Health Information Management Association endorses CMS’s timeline. "Obviously the cost of implementation for ICD-10 will only grow the longer we delay initiating that process," AHIMA says.

"There’s never a good time or enough time to do a conversion like this," says Bob Wardwell of the Visiting Nurse Associations of America. "The training and systems changes needed to accommodate this [conversion] would warrant more time, a much better orientation of the field than the Department of Health and Human Services has provided, and a commitment to fund the changes."

The key to transitioning is training for all staff, which is doable by 2011, estimates Judy Adams of LarsonAllen in Charlotte, N.C. But the more critical area may be the ability to have all of the electronic changes made to accept a different code structure in electronic records and paper forms, plus the re-programming for agencies to have the new ICD-10 coding information incorporated within their systems.

On the other hand: "I believe the clinicians who tell me that ICD-10 is a much better, more specific, and modern classification system -- and [the conversion] needs to be done," says Wardwell. But putting in place things such as a clear cross-walk between ICD-10 codes and all the ICD-9 codes that are integral with the HHPPS system should be done before HHS decrees a conversion time line, he adds.

"I am looking forward to [the conversion] because of the greater specificity for coding and the opportunity to code situations that are difficult to code under ICD-9," Adams says.

For example: Two of the most positive aspects of ICD-10 are the concept of laterality that will allow coders to indicate which side of the body is involved (or whether the condition is bilateral) and the combination of a number of situations into one code, such as the location and stage of a pressure ulcer. This greater specificity will enable home health coders to clearly document their patients’ situations and really help to support the appropriateness of home health and hospice care, Adams says. v