Proposed 1 Year Delay in ICD-10 Implementation

On Tuesday, April 17, 2012, the Department of Health and Human Services published a proposed rule, entitled " Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to the Compliance Date for ICD–10–CM and ICD–10–PCS Medical Data Code Sets"

The proposed rule can be downloaded at: http://www.gpo.gov/fdsys/pkg/FR-2012-04-17/pdf/2012-8718.pdf

In addition to a proposed delay in the compliance date for ICD-10 (to October 1, 2014), there are proposals for a Unique Health Plan Identifier, and an identifier for entities that currently cannot obtain an NPI.

Comments on the proposed rule are being accepted until May 17, 2012 at 5:00pm EST.

Code Numbers Instead of a Narrative Diagnosis

All too often, we see a diagnosis code written in the medical record, in lieu of a narrative diagnosis.  In those instances, we cannot code what has been written for two important reasons:

• Coding is done based on the narrative documentation in the medical record--with no narrative, no coding can take place
• There's no way of telling if the diagnosis code in the chart is correct (i.e., what the provider meant to code)

We get this question at least once a year--and sometimes it leads to lively exchanges.  Thankfully, Coding Clinic, Q1 2012, has decided to address it.  Their answer, in part reads:

"There are regulatory and accreditation directives that require providers to supply documentation in order to support code assignment. Providers need to have the ability to specifically document the patient's diagnosis, condition, and/or problem. Therefore, it is not appropriate for providers to list the code number or select a code number from a list of codes in place of a written diagnosis."

So--the next time you're asked if a provider can just write the code in the chart--you'll know where to point them for clear guidance.

Keeping Up with What's New in Medicare

The Medicare program is massive, and ever changing.  Changes come out several times a year--Part A changes around September, Part B changes in January.  Add that to changes in ICD-9 and CPT, changes in your commercial business--it's all a bit much.

How can you keep up with all these changes? The CMS website is difficult to navigate--and finding things is complicated. 

But, one great place to bookmark and visit frequently is the Medlearn Matters webpage.  This page has educational materials about new Medicare programs and coverage. It's a great way to keep up with what's new in Medicare.  https://www.cms.gov/MLNProducts/

In addition, there's a Medlearns Product Catalog, that allows you to order certain printed matter.  You can view the catalog at https://www.cms.gov/MLNProducts/downloads/MLNCatalog.pdf

You can learn about EHR incentives, the annual wellness exam, and even take online training courses, some of which have CEUs for coders.

Although you won't find everything there--you will find a lot of information about new and changed programs on the Medlearn Home page.

Medical Records Amendments

Palmetto GBA, the Jurisdiction 1 Medicare Administrative Contractor, has published a great article on Medical Record Amendments.  We get a lot of questions about these amendments, and there's very little in writing about them.  The Palmetto article is consistent with what CMS has told Medicare Advantage plans on conference calls--that these amendments should be rare, and should be done within a few days of the original medical record entry.

You can read the article here.
Do you have coding or medical records questions? You can always submit them to us at coding@scanhealthplan.com.

Upcoming CMS Conference Call

On March 28, 2012, from 2:30-4:00 pm EST, CMS will host a conference call on the Initial Preventive Physical Examination (IPPE, also called the "Welcome to Medicare Physical") and the Annual Wellness Visit.

If you are interested, you can register here.

Question of the Month

In the past two weeks, I've received or been asked some variation of the following question:

"Now that CMS is postponing ICD-10 implementation, can I stop or slow down my work on ICD-10?"

First, CMS has not postponed ICD-10, they are considering "postponing compliance for some entities"--postponing compliance (i.e., they won't penalize you for a given period of time) is different than postponing implementation.  At this point, we don't know who is affected, or for how long.

ICD-10 is coming. Although the compliance period may stretch past October 1, 2013, the Department of Health and Human Services (HHS) and CMS have not indicated a cancellation.  Understanding the impact of ICD-10 on your organization is still critical.  There is much to be done, and physicians, their staff, and hospitals must begin (continue) to assess how their current documentation and systems must change and improve in order to meet the realities of ICD-10.

I was reading an ICD-10 article the other day, and I was struck by something.  The ICD-9 was implemented in 1979.  That year, the Nobel Prize in Physiology or Medicine was given to Allan M. Cormack and Godfrey N. Hounsfield for their development of CT Scanning!  Although CT scanners are still a useful tool today--the state of medical knowledge and technology has grown by leaps and bounds in those 33 years.  ICD-9 as a coding system is too limited to have grown with it.   In order to keep pace with the science of medicine, we must move to ICD-10.

Don't stop now---don't even slow down.  There's too much work to be done.   We know it can be overwhelming.  Start with your top 10 diagnosis codes in ICD-9--and look at the possible equivalent codes in ICD-10, using a tool like the 2012 General Equivalence Mappings.  Will your current documentation support an appropriate code in ICD-10? If not, what changes are needed? Simply defaulting to a "not otherwise specified" code may not be enough.

In an Internal Medicine practice, there are large areas with a lot of impact--Diabetes, CVAs, acute MIs--all of these have many increased codes, and complexity.  Taking a look at your documentation now will help you understand where you need to make changes to support the codes that best describe your patient's illnesses.

As to the compliance postponement---we'll be monitoring HHS and CMS websites daily.  When more information becomes available, we'll be sure to post it here.

Recent Coding Clinic Decisions

Coding Clinic has been very busy the last few months.  A number of questions addressed have implications for everyday coding:

Coding Clinic (Q3 2011) was asked what the correct coding for a diagnostic statement of depression and anxiety.  Coding Clinic advised that the correct coding was 311 and 300.00, NOT 300.4, because the physician had not established a linkage between the two conditions.

Coding Clinic (Q3 2011) was also asked about the clinical significance of obesity or morbid obesity, when the physician does not do any further assessment, monitoring or care for the condition.   Coding Clinic indicated that these patients are at increased risk of certain medical conditions, and that they should be coded when documented by the physician.

The question of a diagnostic statement of "pneumonia with hemoptysis" was raised. Coding Clinic (Q3 2011) pointed out that hemoptysis is a Chapter 16 code, and as such should not be coded if it was integral to a disease process.
Finally, in Q4 2011, Coding Clinic was asked how a diagnosis of chemotherapy induced pancytopenia was coded.  The questioner was advised to code 284.11, Antineoplastic chemotherapy induced pancytopenia.  Further, the questioner was told that it was unnecessary to code E933.1, Antineoplastic and immunosuppressive drugs, since it was inherent in the title of 284.11.  However, providers could choose to capture this information if they wished.

We'll continue to monitor Coding Clinic rulings, and provide you information here.