Tip: Review the Federal Register to update charge forms Get a Grip on the New Rule Follow these examples for coding under CMS' new rule: 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.
You once had 90 days to implement new ICD-9 and HCPCS codes -- but not anymore, thanks to a recent CMS ruling issued in two Feb. 6 CMS transmittals (Nos. 89 and 95). The new rule, however, shouldn't cause your pulmonology practice 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 have to begin using new and revised ICD-9 codes when CMS introduces them on Oct. 1, 2004. You will not have 90 days to continue using the old codes. For HCPCS Level 1 (CPT) and Level II codes, the new grace-period ruling becomes effective on Jan. 1, 2005.
Example #1: Last Oct. 1, 2003, Medicare revised bronchitis ICD-9 codes 491.20 (Obstructive chronic bronchitis; without exacerbation) and 491.21 (... with [acute] exacerbation). Under the grace period, most Medicare carriers would accept the old bronchitis codes until Dec. 31, 2003. Without the grace period, however, you should report the revised 491.20-491.21 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 90698 (Diphtheria, tetanus toxoids, acellular pertussis vaccine, haemophilus influenza Type B, and poliovirus vaccine, inactivated [DTaP-Hib-IPV], for intramuscular use) to eliminate using multiple codes for this vaccine. Medicare gave you until March 31, 2004, to begin reporting 90698. But next year you will have to begin assigning new codes on Jan. 1, 2005, the day they take effect.
Spread the Word About New Codes
Note: To access the Register online, go to http://www.gpoaccess.gov/fr/index.html.