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ICD-10 execution date proposed: October 1, 2011

Radiology Administrator's Compliance and Reimbursement Insider, November 1, 2008

ICD-10 execution date proposed: October 1, 2011

ICD-10 no longer represents some distant, implausible menace. Years of speculation came to a sudden end August 15. That’s when the U.S. Department of Health and Human Services (HHS) released its proposed regulation for the transition to ICD-10-CM for diagnostic coding affecting inpatient and outpatient settings and ICD-10-PCS for inpatient procedures only.

Coders have thought about this transition for more than a decade. But when it comes, ICD-10 will change nearly every dimension of hospital operations. The conversion affects payers, software vendors, researchers, regulators, and data warehouses. And, yes, it affects radiology administrators too.

You have three years to get ready, unless the timetable changes in the final rule (which was unavailable at presstime).

“The conversion to ICD-10-CM is going to be challenging, but it is long overdue and definitely worth the effort,” says Jackie Miller, RHIA, CPC, vice president of product development at Coding Metrix, Inc., in Powder Springs, GA.

Disease classification history

HHS adopted the ICD-9-CM code sets in 2000, under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Public and private healthcare organizations use these codes to report healthcare diagnoses and inpatient hospital procedures.

But ICD-9-CM was developed almost 30 years ago. It is widely viewed as outdated due to its limited ability to accommodate new procedures and diagnoses.

“There have been many changes in the past three decades, not just in our knowledge of diseases and disease classification, but also in the ways in which encoded data are used,” Miller says.

ICD-9-CM is not large or flexible enough to meet today’s needs. It contains only 17,000 codes and is expected to start running out of available codes next year, HHS notes.

By contrast, the ICD-10 code sets contain more than 155,000 codes and accommodate a host of new diagnoses and procedures.

“The U.S. is the only industrialized nation in the world still using ICD-9. We have delayed the implementation of ICD-10 over and over and over again,” says Miller, “but waiting is not going to make the transition any easier.”

The additional codes will help enable the implementation of electronic health records because they will provide more detail in the electronic transactions.

This level of detail will also improve efficiencies by helping identify specific health conditions, according to HHS.

Coding future

HHS states that updated versions of current HIPAA electronic transaction standards will require the use of the ICD-10 code sets for claims, remittance advice, eligibility inquiries, referral authorization, and other widely used transactions. The currently adopted standard, Version 4010/4010A1 of the Accredited Standards Committee X12 group, cannot accommodate the much larger ICD-10 code sets.

Under the updated transaction standards proposed rule, compliance with Version 5010 (healthcare transactions) and Version D.0 (pharmacy claims) would be required by April 1, 2010.

Transition steps

The following is a look at what the transition will require:

• Software switch. For radiology providers, the transition requires software changes to accommodate the additional digits of the ICD-10-CM diagnosis codes, says Miller.

“But software vendors have been anticipating this change for many years, and they should certainly have a plan to accomplish the change,” she says.

Several health information management (HIM) vendors already have ICD-10-compliant products due to implementation of ICD-10 in nations such as Canada, Ireland, and England, says Gloryanne Bryant, BS, RHIA, RHIT, CCS, senior director of coding and HIM compliance at Catholic Healthcare West in San Francisco.

Large and small facilities need to have formal vendor assessments conducted, much like those in use during Y2K and HIPAA preparation. This is the time for asking vendors tough questions, Bryant says. Some questions to ask include:

• Are vendors ready?
• If not, when are they going to be ready?
• How are they going to adjust?
• Can they conduct testing and crosswalks?
• Is there going to be a cost to compliance?

Another question HIM and information technology departments have to address is the moment of transition itself. “With October 1, 2011, [as] implementation day, what happens on September 30?” says DeAnne W. Bloomquist, RHIT, CCS, chief consultant and president of Mid-Continent Coding, Inc., in Overland Park, KS. Bloomquist forecasts that providers will have to hold claims for a week or more before and after the transition.

“We have learned from both Y2K and HIPAA, as well as what other nations have done for implementation. There may be some delay in the first week or so, and we’ll have to plan accordingly,” Bryant says, adding that developers must conduct thorough testing of crosswalks before implementation.

• Staff training. The transition also requires staff training, says Miller. There are already many books, online courses, and other training aids available on the market, and there will be more once a firm transition date is set. 

“The guidelines for ICD-10-CM coding are very similar to those for ICD-9-CM, so coders will not find the new system totally strange,” she says. 

When the American Health Information Management Association performed a pilot test of ICD-10-CM a few years ago, most participants found it relatively easy to use, says Miller. But be patient, because any type of transition can be difficult.

“Keep in mind that your staff productivity temporarily may be affected during the transition,” says Stacie L. Buck, RHIA, CCS-P, LHRM, RCC, CIC, vice president of Southeast Radiology Management in Stuart, FL. “Many radiology coders have the most common codes committed to memory, and with ICD-10, they will be faced with learning brand-new codes for every diagnosis and sign or symptom.”

Radiology providers may wish to consider employing computer-assisted coding to increase productivity, Buck adds.

• Revision of charge tickets. The transition will require revision of any charge tickets that include ICD-9-CM codes. “This will be a one-time effort, following which the yearly updates will be no more labor-intensive than they currently are with ICD-9-CM,” Miller says.

On the payer side, coverage policies (driven by diagnosis codes) will need to be revised to include the applicable ICD-10 codes, she adds.

Although there will not be a one-to-one correspondence between ICD-9-CM and ICD-10 codes, there are already crosswalks available to make the conversion easier, says Miller.

Insider sources

DeAnne W. Bloomquist, RHIT, CCS, chief consultant and president, Mid-Continent Coding, Inc., 7300 West 110th Street, Suite 700, Overland Park, KS 66210, 316/214-5157; dee@mccoding.com.

Gloryanne Bryant, BS, RHIA, RHIT, CCS, senior director, coding/HIM compliance, Catholic Healthcare West, 185 Berry Street, Suite 300, San Francisco, CA 94107-1739, 415/438-5721; gbryant@chw.edu.

Stacie L. Buck, RHIA, CCS-P, LHRM, RCC, CIC, vice president, Southeast Radiology Management, 512 Southwest St. Lucie Cres-cent, Stuart, FL 34994, 772/600-0324; stacie@southeastrad.com.

Jackie Miller, RHIA, CPC, vice president, product development, Coding Metrix, Inc., 5041 Dallas Highway, Suite 606, Powder Springs, GA 30127; jackie.miller@codingstrategies.com.

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