NAHC Offers Tips for ICD-10 Preparations
June 15, 2015 09:39 AM
The implementation date for the ICD-10 is fast approaching. All providers, health plans, and clearinghouses must comply with ICD-10 regulations as ‘covered entities’ under the Health Insurance Portability and Accountability Act (HIPAA). The National Association for Home Care & Hospice (NAHC) has heard reports of varying levels of preparedness among home health and hospice providers. Some providers have been preparing for some time, while others have made little effort towards preparations.
NAHC urges agencies that have not begun preparation or have invested little in terms of preparations to begin NOW; Oct 1 will be upon us sooner than you think. Although late in the game, there is still time for meaningful progress.
The first step is to assign a team responsible for ICD-10 preparations. This could be one or several individuals, depending on your agency size, who is/are aware of the gaps and can coordinate efforts to aid in improving preparedness. Next, the agencies need to conduct a gap analysis. A gap analysis allows the agency to understand where they are and what they need to do to reach their goal.
During the gap analysis examine the processes for all departments. For example, is the billing department up to the task and will your software vendors be ready in time for the conversion? Have any of your staff been trained and which staff members? Keep in mind: just about all staff members have a role, not just the coders. The ICD-10 code selection will be dependent on documentation from both the referral source and the assessing clinicians. Supervisors and the quality performance team will need to understand ICD-10 coding to ensure the most accurate code has been selected.
Because there will be a heavy reliance on documentation, agencies will need to work with their referral sources in obtaining as much information as possible. Agency staff should be trained to ensure their documentation reflects accurate information related to diagnoses to allow for ICD-10 specificity. Home health agencies should be aware that the Centers for Medicare & Medicaid Services (CMS) has eliminated many of the “unspecified” codes from the 2015 home health prospective payment system (HHPPS) Grouper. CMS believes that the majority of the codes that have been eliminated contain information agencies should be able to readily identify, such as, laterality of an affected limb.
NAHC has heard that some agencies are not training any staff, even coders, because they believe that their software vendor will be able to simply apply the General Equivalence Mapping (GEM) translation. The GEM is not intended to be used as a crosswalk between ICD -9 and ICD-10. Many codes do not have a one to one translation between ICD-9 to ICD-10. Therefore, agencies will need to relay on clinical documentation to code accurately.
An important part of training and preparation for ICD-10 is developing a dual coding system to match how the current ICD-9 codes will translate into ICD-10. Agencies can approach dual coding in several ways. For example, dual code all records, if feasible, or select the most common diagnoses seen by the agencies and begin listing appropriate ICD-10 codes. Dual coding will serve to increase accuracy in coding for all providers, and for home health agencies also provide a financial analysis. It is unclear how much change there will be in payments to home health agencies as a result of the conversion from ICD-9 to ICD-10.
Another key aspect to consider for a smooth transition is to ensure your software vendors are ready, not only for the conversion, but for testing with trading partners. Some providers have not been able to participate in end to end testing exercises because their software vendor was not ready to participate. In addition, most agencies will need their software vendor’s assistance in order to dual code. Agencies must understand where their software vendors are in terms of readiness and any contingency plans. CMS has finally released the 2015 HHPPS Grouper which will allow agencies and vendors to progress in their preparations.
It is necessary for agencies to engage with their payer sources and clearinghouses as part of their readiness plan for ICD-10 implementation. Once your agency is ready to covert to ICD-10, testing with trading partners to ensure their readiness is imperative. The agency’s readiness for ICD-10 implementation is only half of the equation for a complete transition.
For agencies that need assistance with preparation, working with a consultant that specializes in home health and/or hospice operations may be the best approach. NAHC has on it web site an ICD-10 resource page that list tools and materials contributed by home health and hospice consultants to assist providers to prepare for the conversion. Agencies contemplating this approach should contact a consultant as soon as possible or you may not be able receive the assistance you need in time.
In addition to consultants, many agencies have chosen to outsource their coding, which is another good option. However, agencies will still need to determine whether the organization conducting the coding can meet the agency’s needs. Productivity standards and accuracy in coding should be part any negotiation. Agencies are ultimately responsible for the product(s) produced by outside contractors. Similar to contracting with consultants, agencies will need to move soon if outsourcing is how they choose to proceed.
Regardless of the level for which providers are prepared or whether the coding will be handled internally or externally, be assured there will be claims processing problems and potential delay in payments. The degree of disruption remains to be seen, but all health care providers should be financially prepared for prolonged delays. Some industry experts recommend providers have funds, either cash on hand or a line of credit, to maintain operations for three to six months.
Although Medicare is not the only payer that will be impacted by the conversion to ICD-10, they are largest payer for most home health and hospice providers. At this point, CMS has not provided any information specific to home health and hospice. The majority of the information is either very general or geared towards physician practices. NAHC has been in contact with a CMS contractor for ICD-10 implementation about their plans for a webinar specific to home health and hospice providers, but no details have been provided.
In addition, home health agencies have some unique issues with the ICD-10 conversion; both in terms of the complexity of coding that will be required for claims that span October 2015 and the potential impact on payments. NAHC is drafting a letter to CMS officials that addresses some of the concerns with the ICD-10 implementation. The letter will be shared with members in a follow-up NAHC report article.