Oncology & Hematology Coding Alert

CMS Announced End To Flexibilities Beyond Oct. 1, 2016

Practices have no option but to adopt specificity and accuracy.

ICD-10-CM codes apply to your diagnosis coding. To meet the coding requirements, there are three key steps that you should adopt:

  1. Keep up with any changes in payer policies
  2. Identify new/deleted/revised codes
  3. Implement changes in the most effective and seamless manner

No scope for flexibility: The CMS has clearly specified ‘The ICD-10 flexibilities expire on October 1, 2016’ in the information for ‘expiration of Medicare flexibilities’ in the document on clarifying questions and answers. The document is called “Clarifying Questions and Answers Related to the July 6, 2015, CMS/AMA Joint Announcement and Guidance Regarding ICD-10 Flexibilities.” The update was made on August 18, 2016. You can access the document at: https://www.cms.gov/Medicare/Coding/ICD10/Clarifying-Questions-and-Answers-Related-to-the-July-6-2015-CMS-AMA-Joint-Announcement.pdf.

Target specific codes: CMS urges you to avoid using unspecified ICD-10 codes, and make your best effort to report a more detailed code based on the documentation. Do not expect Medicare to phase in the requirement to code to the highest level of specificity either. Providers are expected to have achieved competence in coding specificity by now. In fact, certain insurers did not choose to offer coding flexibility to begin with, so many providers are already using specific codes. Nevertheless, you will need to brace yourself so that your coding accurately reflects the clinical documentation in as much specificity as possible, in accordance with the requisite coding guidelines.

‘The provider community should code claims to the degree of specificity supported by the encounter and the medical documentation,’ the CMS has clearly mentioned in the updated document.

Accuracy is key: ICD -10 was implemented to bring forth a greater degree of detail and accuracy in diagnosis reporting. CMS advises you to avoid unspecified ICD-10 codes when your documentation provides you with enough information for a more appropriate code. Double check each claim to ensure that it aligns with the clinical documentation.

“While this year’s update includes many new codes, the new clinical concepts are minimal,” says CMS in its clarification. CMS is well equipped to handle changes to codes and processes, so do not anticipate any delays.

Can you still use unspecified codes? While CMS requires you to report specific diagnosis codes as per the documentation, in some instances, you may have to resort to unspecified codes when there is not enough information available. “You should code each health care encounter to the level of certainty known for that encounter,” says CMS in the document. “When sufficient clinical information is not known or available about a particular health condition to assign a more specific code, it is acceptable to report the appropriate unspecified code (for example, a diagnosis of pneumonia, although the physician has not determined the specific type).” 

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