Otolaryngology Coding Alert

Silver lining: Congress also halts the expected 24 percent physician pay cut.

Otolaryngology physicians and coders have more time to prepare for ICD-10 codes such as H72.01 (Central perforation of tympanic membrane, right ear) and J35.01 (Chronic tonsillitis), thanks to recent legislation. 

Congress and President Obama took steps to avoid the 24 percent pay cut that physician practices were poised to take on April 1 by approving the Protecting Access to Medicare Act of 2014. A small portion of text in the bill led to another big change for physicians that impacts coders of every specialty – a delay of ICD-10 implementation.  

Read on for the latest news and what several coding experts believe practices should do in response.

Breathe a Bit Easier Before the ICD-10 Switch

Mentioned about one-third of the way into the 121-page bill is a short paragraph that states, “The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD–10 code sets  as the standard for code sets.” This means that since the bill has been signed into law, ICD-10 will be delayed for at least another year beyond the scheduled Oct. 1, 2014, implementation date. 

Remember: In recent history, this is the second time ICD-10 implementation has been delayed. The original compliance date of October 1, 2013 was officially pushed back a year on September 5, 2012 by CMS. According to CMS this additional one-year delay of ICD-10 will likely cost the industry an additional $1 to $6.6 billion on top of the costs already incurred from the previous one-year delay.

AHIMA’s take: The American Health Information Management Association (AHIMA) spoke out against the delay. In a March 31 press release, AHIMA CEO Lynne Thomas Gordon, MBA, RHIA, CAE, FACHE, FAHIMA, states: “On behalf of our more than 72,000 members who have prepared for ICD-10 in good faith, AHIMA will seek immediate clarification on a number of technical issues such as the exact length of the delay.” 

The press release goes on to say “Since the transition to ICD-10 remains inevitable and time-sensitive because of the potential risk to public health and the need to track, identify and analyze new clinical services and treatments available for patients, AHIMA will continue to help lend technical assistance and training to stakeholders as they are forced to navigate the challenge of continuing to prepare for ICD-10 while still using ICD-9.”

Duane Abbey, Ph.D., from Abbey & Abbey, Consultants, Inc., in Ames, IA., raises another question: “If we are not implementing ICD-10, then will ICD-9 be updated?” The process for updating ICD-9 essentially has been suspended with the expectation of ICD-10 implementation.

Don’t Stop Your ICD-10 Preparations 

While many feel this new law and resulting ICD-10 implementation delay is not good for practices, there may be a small silver lining. 

“I think it is a bad thing because it affects our momentum to crossing the finish line,” explains Laureen Jandroep, CPC, CPC-I, CMSCS, CHCI, senior instructor with CodingCertification.org in Oceanville, N.J.  “However we can use the extra time to prepare even more thoroughly so we can make the best of it.  For those that have made the investment getting ready it is frustrating to see their investment loose traction.”

Despite the delay in implementation, experts warn that practices must continue their efforts to preparing for ICD-10 use. “Part of the reason we’re in this situation is not enough people have prepared and petitioned for more time,” Jandroep says. “It is not fair to those that did prepare and are ready or were going to be by the 10/1/2014 date. The changes are in the implementation date, not that it is not coming at all, so prepare on!”

“Of note, we should not throw away the chance to improve the physician’s clinical documentation just because the code set implementation has been delayed,” adds Barbara J. Cobuzzi, MBA, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a consulting firm in Tinton Falls, N.J. “It is always a goal to improve clinical documentation.”

Don’t Expect a Permanent SGR Fix This Time

In late March, Congress introduced the Protecting Access to Medicare Act of 2014 (HR 4302), which halted the expected 24 percent physician pay cut for the rest of the year. The House of Representatives quickly passed the bill on March 27, and the Senate passed it on March 31. President Obama then signed the bill into law on April 1.

The newly passed law replaces the reimbursement cut with a 0.5 percent payment update through the end of 2014 and a zero percent payment update from January 1, 2015 to March 31, 2015. 

Bad news: This new legislation only provides a temporary solution, not a permanent fix to the Medicare sustainable growth rate (SGR) formula that leads to these looming pay cuts every year. Many industry groups are lamenting the lack of a long-term solution. 

“Full repeal of the sustainable growth rate formula is the answer to strengthening the Medicare program, not another patch,” American Medical Association president Ardis Dee Hoven said in a March 26 statement urging Congress to not even pass the bill. 

“The SGR needs to be fixed permanently by Congress,” agrees Catherine Brink, BS, CMM, CPC, CMSCS, president of Healthcare Resource Management, Inc. in Spring Lake, NJ. “The temporary fix at least keeps practices’ Medicare revenue on track for now anyway.”

“This means we will be going through this again in a year,” Cobuzzi adds. “The AMA has spent a year working with Congress trying to get a permanent fix and then they bailed at the finish line because nothing seems to be able to be accomplished. Congress is not willing to commit to the cost for the fix.  The reality is that they have been kicking the can down the road for many years and each year, we are incurring the cost of not reducing the fees.”