Health Information Management

CMS releases new ICD-10 FAQs

APCs Insider, June 14, 2013

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By Michelle A. Leppert, CPC

CMS released three FAQs about ICD-10 billing, including how to bill encounters that cross the ICD-10 implementation date. That’s October 1, 2014 in case you forgot. And a claim cannot contain both ICD-9 and ICD-10-CM codes. So what to do you?
While the FAQ doesn’t provide much information, CMS did release Special Edition MLN Matters® Article SE1325 that contains detailed information about how to handle encounters that cross the implementation date.
 In some cases, providers will need to report ICD-9 codes on one bill for services before October 1, 2014, and a second bill with ICD-10 codes for services after October 1, 2014.
Providers must split the claim so all ICD-9 codes remain on one claim and all ICD-10 codes remain on the other claim for these bill types, among others:
  • Inpatient Part B hospital services (bill type 12x)
  • Outpatient hospital (bill type 13x)
  • Outpatient therapy (bill type 74x)
  • Comprehensive outpatient rehab facilities (bill type 75x)
Anesthesia services that begin September 30, 2014, but end October 1, 2014, should be billed with ICD-9-CM codes and use September 30, 2014, as both the from and through dates.
A single item service with a time frame that crosses over midnight on September 30, 2014 (e.g., ED visits and observation) is not split into two separate charges. The single item service should be placed in the claim based upon the line item date of service (LIDOS). For ED encounters, the LIDOS is the date the patient enters the ED.
For observation encounters, it is the date that observation care begins.
CMS also issued an FAQ regarding HIPAA compliance for claims submitted with ICD-9 code after October 1, 2014. The short answer: The date of service determines which code set coders should use regardless of the date the claim is filed or submitted.
The third FAQ deals with the common question of how long will ICD-9 codes hang around after October 1, 2014. CMS’ answer, not surprisingly, is that it depends on your payer.

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