The ICD-10 final rule, CMS-0013-F, was published on January 16, 2009. Basically, that's when they gave us a decision that, “Yes, we're going to go ahead and move to ICD-10.” For years, they said ICD-9 is going to move to ICD-10. Many other countries have already been using that. But this is the final healthcare rule which means it is law, we have to do it.
The compliance date is October 1, 2014. Any of you who've worked with NPI, the National Provider Identifier, you know there were delays from time to time and some of the other programs, the red flag rule, that's been delayed several times, et cetera.
You current procedural terminology which generally codes your out-patient evaluation and management and out-patient procedures, that remains the same. You'll have your annual coding updates as you do now but there is no major change on your HCPCS, healthcare procedural - so forth.
Medical coding system on your supplies, drugs, et cetera – those also will remain in the same format that they currently are in, just you'll have your annual updates.
There will be a single implementation date for all users with the NPI. The small providers have an extra year to prepare for that. In this particular case, for ICD-10, all users – no exceptions – will need to implement ICD-10 by October 1, 2014.
For in-patient it's the date of discharge for in-patient settings. There's been a lot of questions as to, “What if our patient is transferred to another facility or they've been discharged and re-admitted or they've been transferred from ER to in-patient and it's overnight, September 30th to October 1st? What do you use, et cetera?”
And so it's the date of discharge for in-patient settings. And they tell us there's more guidance to come. Lots of questions being raised about that and they will give us more guidance.
For conversion implications, there are many implications. Billing and cost, how are we going to bill? When do we bill, et cetera? What's it going to cost us to implement all these and to make all these medical coding and billing changes?
Reimbursement, how does that affect our reimbursement from the payers, the insurers, Medicare, Medicaid, et cetera? Do they all have to comply as well? And yes, they do.
Data collection, for those of you who are involved in data collection and analysis, for a period of time, you're going to be collecting data for both ICD-9 and ICD-10. If you have a fiscal year from January 1 to December 31, this October 1 is inside that year and so you're going to be working with both ICD-9 and ICD-10 data.
Reporting, if we're reporting after October 1st, do we report by ICD 10 codes or ICD-9 codes, et cetera? We'll need a lot more guidance on that prior to that date.
There are a variety of projections. Some people say it's going to be relatively easy within their own facility. Others say it's going to require a whole new computer system, lots of different projections.
We know there's going to be a lot of effort and expenditures. They will be large. That's just pretty much a given with something that affects these many areas.
It's resource-intensive. You may have to hire additional staff – HIM personnel, IT personnel; just the education now that is going to be resource-intensive.
Some of the cost benefits, how is this going to benefit us? We're going to have more accurate payments for new procedures. Fewer miscoded, rejected and improper reimbursement claims; and of course, that's based on your coders if they're submitting these claims correctly and understand ICD-10.
Better understanding of the value of new procedures and so your resource base value scale, et cetera, your fee schedules – all of that will be adjusted based on these ICD codes.
Improved disease management: There is going to be more information in a specific code and so you're going to have improved disease management. What complications do these patients have? What morbidity do they have with that particular condition? And a better understanding of healthcare outcomes.
All of this is going to be more specific and give us more information. And of course it's going to affect our quality programs, too. It will give us more specific information to implement new quality programs.
When should coders learn ICD-10?: Organization leaders and instructors should begin ICD 10 training. They should educate themselves now. Intensive coder training is recommended at six to nine months before implementation. So if you're coding on a day-to-day basis and you want to learn ICD-10 now, it could be somewhat confusing because some of the guidance, some of the rules are a little different.
And so they recommend that intensive training for your coders begin six to nine months before implementation, the implementation date of October 1, 2014.
It's recommended that there are 16 hours of ICD-10 CM for most coders. So some of the basic coding rules you know now are certainly going to apply at that time.
You’re going to take a lot of your medical coding rules, a lot of what you know now, your anatomy, physiology, reading a chart, picking out diagnoses and procedures, et cetera. You're going to apply those same skills to ICD-10.
Additional training on anatomy, physiology, pathophysiology, et cetera, and terminology is recommended. PCS for in-patient coders is more complicated and it's going to take a little longer because the format, the structure is very different than ICD-9.
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