It’s time for those still advocating a delay of ICD-10 to abandon the fight—but they can take heart in the recent concessions offered by CMS. The AMA, concerned about the complexity of ICD-10, has asked for some measure of protection from potential adverse financial impacts of the transition to the new code set, and CMS recently agreed to a one-year compromise.
Recognizing the challenges for providers, CMS has agreed:
- Not to deny claims based on the (lack of, or incorrect) specificity of the ICD-10 code, as long as the reported code is a valid code from the right family of codes.
- Not to subject providers to penalties under 2015 quality reporting programs, (Meaningful Use, PQRS, or the Value-Based Payment Modifier), as long as a valid code from the right family is reported for the measure(s).
- To create an ICD-10 Ombudsman to help negotiate solutions to ICD-10 related problems.
CMS has also acknowledged realistic challenges on its side, and is insulating providers from resulting financial harm by agreeing:
- To authorize advance payments if Medicare contractors are unable to process claims in a timely fashion (as defined by CMS) due to problems with ICD-10.
- Not to penalize providers under MU, PQRS, or the V-BPM if CMS “experiences difficulty calculating the quality scores.”
You can read about the above in CMS’ own words in its FAQ document.
Notwithstanding the above, it’s time to get serious about preparing for the transition to ICD-10, if you have not already begun that process. Fortunately, there are some ICD-10 solutions embedded in EHRs and PM systems that make code selection easier than others, but regardless of the particular system you employ, there is a learning curve for physicians, clinical teams, and billing staff members.