Medicare Compliance & Reimbursement

Non-covered entities are not required to make the transition to ICD-10.

If you think all your bases are covered for the transition to ICD-10 once your coders and billers have learned the new codes and the software has been updated, think again. Make sure to take these additional steps between now and the implementation date, suggested experts during CMS’s March 13 webinar, “ICD-10 Overview: Basics and Transition Tips.”

Keep An Eye on ‘Non-Covered’ Entities

Although Medicare, Medicaid, and most private health plans will be required to use ICD-10 codes once the transition date arrives, keep in mind that “non-covered entities” are not subject to that rule.

“Non-covered entities includes workers’ compensation, auto, property and casualty insurers, and these entities are not required to make the transition to ICD-10,” said ICD-10 trainer Mandy Willis, CCS, CPEHR, during the call. “However, there are a number of benefits associated with ICD-10 like greater detail in injury codes and seamless communication when filing for coordination of benefits,” she added. Therefore, some of these insurers, although not required to do so, will start taking ICD-10 codes. You should contact your non-covered entities to find out what their claim submission requirements will be, Willis advised.

Don’t Be Daunted by Size of Code set

Although you’ll see your diagnosis coding options go from 14,000 codes under ICD-9 to about 69,000 codes under ICD-10, don’t let that stop you from educating your staff members thoroughly about the coding rules. In reality, Willis said, the ICD-10 code book is similar to the old White Pages phone books that we all used religiously. It may be stuffed with numbers, but you’ll only use the finite set of them that are most applicable to you. This is similar to the current coding structure, “since you probably only use a fraction of the complete list of ICD-9 codes today,” she added.

In addition, if your billing and coding vendors aren’t prepared for ICD-10, that will become your problem, not just the billing company’s, Willis said. “Remember it is the provider’s responsibility to take ownership and contact the billing service regarding their readiness for ICD-10 as well as testing,” she said. “The provider is ultimately responsible for submitting a valid ICD-10 code.”

Tackle Backlogs

Even if you have already talked to your vendors and third-party billing companies about ICD-10 readiness, there’s another issue you should address. If you have a backlog of ICD-9 claims, tackle that now to ensure that you have a smooth transition, Willis said. “You want to be able to focus on ICD-10 productivity and claims issues when they come up,” she advised. Resolving these backlogs is not a requirement before going live with ICD-10, but it’s an industry recommendation to support the smoothest transition possible.

Accurate ICD-10 coding has a ripple effect, since you’ll need to use diagnosis codes on things like radiology and lab requests, and those practitioners will be basing their services on the ICD-10 codes that you report. “It’s extremely important that you work with these entities to ensure a smooth transition, as they are inevitably reliant on the information that you provide in order to maintain their business,” Willis said.

As most readers know, CMS intends to launch an end-to-end ICD-10 testing period in July, which will differ from the current ICD-10 tests. During the more in-depth testing, providers will submit ICD-10 code claims to their MACs and will receive a remittance advice and adjudication.