You will no longer have a 90-day grace period to implement new ICD-9 and HCPCS codes, thanks to HIPAA requirements, according to two Feb. 6 CMS transmittals (Nos. 89 and 95). But the change shouldn't cause you many problems, coding experts say.
The grace period allowed providers "to ascertain the new codes and learn about the discontinued codes," CMS says. But HIPAA's "transaction and code set rule" mandates that physicians and practices report codes that are valid at the time the physician rendered the service. Therefore, you will no longer have a 90-day grace period for billing discontinued ICD-9 codes starting Oct. 1, 2004. The grace-period ruling becomes effective for HCPCS Level I and Level II on Jan. 1, 2005.
Example #1: Last Oct. 1, 2003, Medicare introduced diagnosis codes 282.41 (Sickle-cell thalassemia without crisis), 282.42 (Sickle-cell thalassemia with crisis) and 282.49 (Other thalassemia), which replaced 282.4 (Thalassemias). Under the grace period, most Medicare carriers would accept deleted code 282.4 until Dec. 31, 2003. Without the grace period, however, you should report 282.41-282.49 on Oct. 1, or your Medicare payer would probably deny your claim.
Example #2: Remember that CMS' grace-period elimination also applies to new HCPCS codes. For instance, on Jan. 1, 2004, CPT introduced 78804 (Radiopharmaceutical localization of tumor or distribution of radiopharmaceutical agent[s]; whole body, requiring two or more days imaging) to replace deleted G0273 (Radiopharmaceutical biodistribution, single or multiple scans on one or more days, pretreatment planning for radiopharmaceutical therapy of non-Hodgkin's lymphoma, includes administration of radiopharmaceutical [e.g., radiolabeled antibodies]). Medicare gives you until March 31, 2004, to begin using 78804 instead of G0273. But next year you will have to begin reporting new CPT codes on Jan. 1, 2005, the day they become effective.
What to do: You shouldn't encounter many coding difficulties or denials without a grace period as long as you update your encounter forms by the ICD-9 and HCPCS' deadlines, says Melanie Witt, RN, CPC, MA, an independent coding consulting in Fredericksburg, Va. The Federal Register usually publishes new codes well in advance of their release, so you should have enough time to make the changes, she adds.