ICD 10 Implementation Update 60 Days In – Still No Major Issues

-->November 30, 2015Billing & Compliance Alerts

    The transition to ICD 10 continues to be very smooth.  We have encountered no major issues.  We have encountered random denials and sporadic claim errors, however, but no issues we were not able to quickly identify and resolve.   For those wondering how this massive change could have happened so quietly, I believe there are three main reasons:

    First – Medac Preparation

    Medac understood the importance of not only surviving this transition, but finding ways to improve through it.  We modified numerous systems not just to accept the new ICD 10 codes, but to optimize system performance and user efficiency to aid in accuracy and to offset the expected production impact.  We trained our staff 2 years ago and practiced in ICD 10 for months.  We established a “SWAT” team to review and address all issues pertaining to ICD 10 on a daily basis.   We planned for all issues we could define and had teams in place to attack the risks if they materialized.

    Second – Industry Preparation

    The late 2014 delay and subsequent promises not to delay again apparently got everyone’s attention.  The extra year of preparation paid off across the industry.  The extra time was invaluable for testing the technical connections and processing systems to ensure the codes would be accepted and processed.   The first big fear in this transition was that systems would be incompatible, claims would not be accepted, and codes would be processed incorrectly – the concern was that if even one of the various entities involved in the claims process botched their implementation, the entire process would stop.  These risks simply haven’t materialized.

    Third – It Just Isn’t as Bad as it Could have Been

    One of the biggest concerns going into this transition was the specificity requirements for ICD 10 codes.   Everyone can agree the ICD 10 codes include far more detail than their ICD-9 predecessors, but no one was sure exactly how much of these new details the payers would require.  We did notice improvements in the details provided in many accounts, but the ICD 10 requirements in some areas are just too great for an anesthesia provider to reasonably overcome.  We found in our pre-implementation testing that more than 95% of cases could be coded with valid ICD 10 codes with no modifications to documentation practices.   This, of course, relied on a heavy dose of “unspecified” codes which many payers had threatened to not cover.   While there is certainly room for documentation to improve up to ICD 10 standards, most documentation is at least sufficient in its current state.

    What’s Next?

    Threats still remain as payers continue to refine their policies and “tighten the clamps” on what they will cover.   There are 10 months left on the Medicare grace period for specificity – but even this remains unclear (Will Medicare implement the strict specificity policy we all feared 2 months ago, or will it implement a policy similar to what we are seeing with all other payers now, which generally isn’t an issue?).  We are continuing to monitor this transition very closely and will alert you of any specific issues that will directly impact your practice.    I have re-attached the ICD 10 Documentation Resource Guide and re-listed some previously delivered FAQs below.



    Frequently Asked Questions


    Q: What should I expect to happen on October 1st?

    A:  Nothing.  In fact the ICD 10 frenzy may be very quiet through the first week or two of October.  Most payers are implementing ICD 10 starting with October 1st dates of service, so depending on your date-of-service to date-of-bill timeline, your claims may not even get to the payer until well after October 1st.  From there, problems may not surface for a couple more weeks until the payer adjudicates the claims.  Again, Medac has done everything we can to ensure readiness, but a quiet October doesn’t necessarily mean the storm has passed.


    Q: How does my documentation stand against ICD 10 requirements?

    A:  The attached Documentation Resource Guide addresses the deficiencies identified on live cases across all Medac groups.  Most issues were consistent across all groups.  The best way to evaluate your diagnosis documentation against the ICD 10 requirements is to review this guide and compare to what you generally document in each scenario defined.  You will undoubtedly see areas where new items are required that you do not normally capture.


    Q: Does my diagnosis have to match the surgeons?

    A:  The answer is most likely, “no”, but this could be a requirement in some cases.  The key factor is how the payer uses its claim edits.  My belief is that most payers will not take their claim edits this far.  Further, due the significant changes in ICD-10, I believe matching diagnoses across all providers will be nearly unachievable, at least initially.  That said, there is nothing preventing a payer from taking this stance.


    Q:  Are there any tips or general guidelines that will help with ICD 10 documentation?

    A:  The ICD 10 codeset is nearly 4x bigger than the ICD-9 codeset, with each diagnosis range expanding into its own set of specific details.  There is no “silver-bullet” to easily capture all ICD 10 requirements for each diagnosis category.  However, there are some central themes that apply to most categories.  These are:

    • Laterality: Right, left, or bilateral
    • Location: Specific organ/body area, and the specific site on the organ/body area
    • Cause:  Infection due to ___,  injury due to___,  disease due to ____
    • Contributing or Exacerbating Factors:  HTN, Diabetes…
    • Type: If the condition has multiple manifestations, list which is applicable


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    The information presented herein reflects general information that is current as of the date it was first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author’s presentation of this information might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.