Medicare Compliance & Reimbursement

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 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.

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 codeset, 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  ata 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.

Proposal: Next Year Will Be the Last Time ICD-9 is Updated

Vendors, payers, and coding educators have asked CMS to freeze the current diagnosis code set to help make  and Blue Shield of Kansas LCD. The patient will have to pay the facility for the lens (typically over $800), minus the $150 that Medicare will cover.

The beneficiary is responsible for what Medicare doesn't cover if he has decided he wants the PC-IOL instead of the non-PCIOL, clarifies Maggie M. Mac, CPC, CEMC, CHC, CMM, ICCE, director of Best Practices-Network Operations at Mount Sinai Hospital in New York City. "The patient is under no obligation to accept the recommendation of the physician to have the PC-IOL and may elect to have the non-PC-IOL," she explains.

CMS offers no clear advice on what code to use to bill the patient for these extra services, which can include testing like corneal topography or corneal pachymetry as well as added E/M time for pre- and postoperative care.

Experts warn: Don't be tempted to turn to the code for unlisted procedure (66999, Unlisted procedure, anterior segment of eye). That code is for services assumed to be covered by the carrier for which no other CPT code is available.

Since you know that the extra services are not covered, don't submit 66999 to Medicare or any other carrier for the portion of the service deemed to be noncovered. For non-Medicare carriers, you can code these services with HCPCS code S9986 (Not medically necessary service [patient is aware that service not medically necessary]) linked to ICD-9 code 367.4 (Presbyopia). The "S" code is not covered by Medicare statute and, therefore, should not be submitted to your Medicare carriers.

Best approach: Submit a claim to the carrier for the cataract surgery with 66982, 66983, or 66984. Collect the amount for the extra services directly from the patient -- preferably before the surgery.

Note: To read the original ruling, go online to www.cms.gov/Rulings/downloads/CMSR0501.pdf. For the Medicare transmittal with additional coding guidance, visit www.cms.gov/Transmittals/downloads/R636CP.pdf.