Health Information Management

Healthcare News: CMS issues National Coverage Determinations with ICD-10 translations

JustCoding News: Inpatient, June 6, 2012

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by Kimberly Anderwood Hoy, JD, CPC

CMS has issued both a National Coverage Determination (NCD) Transmittal 143 and Medicare Claims Processing Transmittal 2473 on the coverage of extracorporeal photopheresis for the treatment of bronchiolitis obliterans syndrome (BOS) in certain circumstances under clinical research studies.

The NCD and claims instructions are fairly self-explanatory, but CMS’ approach to the ICD-9 to ICD-10 transition in relationship to NCDs is noteworthy.

The title of these transmittals is “Extracorporeal Photopheresis (ICD-10).” From that title, readers might think CMS is addressing specifically the codes for extracorporeal photopheresis in ICD-10 or something similar. However, the transmittals are actually announcing the coverage and billing policies related to new coverage of extracorporeal photopheresis.

The “(ICD-10)” at the end of the title seems to indicate that CMS included ICD-10 information and/or translations in the transmittal, almost like an internal cue to contractors that ICD-10 implementation information is included.

This convention has appeared in a few other transmittals (e.g., screening and behavioral counseling for sexually transmitted infections) that contained ICD-10 coding information in the business requirements for the contractors. These two transmittals, however, contain full tables with the ICD-10 codes that correspond to the ICD-9 codes currently covered in the policy.

The transmittals make the coverage before and after the eventual implementation of ICD-10 very clear. Once concern, however, is the business requirements that instruct the contractors regarding what they should do with this information. Similar to the other transmittals, the business requirements tell contractors to track and add these code(s)/edit(s) to their own systems when applicable. It also states they will not receive a separate change request (transmittal) with further implementation instructions.

This approach could spell trouble for providers. Some Medicare Administrative Contractors (MAC) may be very organized and timely in tracking all transmittals and implementing the ICD-10 covered codes and edits contained in them. Others may experience delays in implementing the codes or miss some because of this scattered approach.

Providers and their contractors will have to be vigilant about cumulating these new policies as they are published rather than being able to count on a more systematic communication of the ICD-10 codes approved for each NCD.

Questions remain regarding how systematic CMS’ approach will be when converting NCDs from ICD-9 to ICD-10 codes. For example, CMS adopted several other behavioral counseling NCDs (e.g., for obesity, cardiovascular disease, and alcohol misuse) at the same time as the one for sexually transmitted infections. However, they do not contain ICD-10 coding information. It is unclear why only one in this series contains ICD-10 information. It remains unclear how CMS will communicate the information for the others in this series of NCDs, as well as the multitude of other NCDs.

As providers prepare for ICD-10, they should monitor this conversion of ICD-9 codes in NCDs, as well as Local Coverage Determinations. Problems with these policies could mean denied claims or processing delays, even when a service is covered and billed with the correct codes, simply because of implementation problems at the contractor level.

Editor’s note: Hoy is director of Medicare and compliance at HCPro, Inc., in Danvers, Mass. This article is adapted from the May 21 issue of Medicare Weekly Update.
 



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