ICD-10 Delayed? Now What?

By Sparkle Sparks, PT, MPT, COS-C
OASIS Answers, Inc.

With last week’s announcement by HHS Secretary Kathleen Sebelius that ICD-10 compliance will be delayed, providers are more confused than ever about what they should be doing to support ICD coding accuracy. While the government sorts this out we’d like to offer some prospective to our many home health clients and friends.OASIS Answers offers coding training for both ICD-9 and ICD-10 and will continue doing so until the government makes some definitive decisions regarding the implementation of ICD-10. ICD-10 is still coming. Secretary Sebelius said that “HHS will initiate a process to postpone the compliance date by which certain health entities have to comply with ICD-10.” The take home message is that ICD-10 is still coming.

What isn’t so clear however, is which entities the delay will apply to, and the delay timeline. Considering the current needs and future uncertainties, we’d like to recommend the following strategy for coding education for home care providers.

Ensure compliance and competence with ICD-9-CM coding. Prior to the news about the postponement of ICD-10 the most common question was, “Why should we continue with ICD-9 training when “10” is on the horizon?” The answer is simple. At the very least we still need to understand and correctly assign ICD-9 codes until 10/1/13. We are mandated by regulations to only enter accurate information in our patients’ records. Erroneous coding can have horrible unintended consequences for the patient whose medical record becomes contaminated by diagnoses that they don’t have. At the home health agency level, coding impacts reimbursement, risk adjustment and impacts quality outcomes. There’s a lot riding on the accurate assignment of codes.

The guidelines (rules) between the ICD-9 and ICD-10 systems remain largely unchanged. The only real changes come in the conventions to accommodate the different structures of the codes in the respective codesets. It is imperative that coders attain the high-level skill of understanding and accurately applying the guidelines and conventions of the system currently in use. And the added benefit of continuing to study ICD-9 is that the more you know about “9” the better off you’ll be when you start to learn “10.” There are more similarities than differences between the two systems; the coding manuals are used in the exact same way; and unless corrected, the current ICD-9 errors of selecting the wrong code or failing to select the correct additional digit, will perpetuate in ICD-10.

For the last year, OASIS Answers has included official citations in our ICD-9 trainings that reference corollary knowledge for ICD-10. We have also created a workshop to offer a preview of ICD-10 based on the recommendations of the World Health Organization (WHO) and the Centers for Medicare Medicaid Services (CMS) regarding education that should be offered now. It provides an overview of the structure and organization of the ICD-10 codeset & codes, introduces new features of the system and offers some perspective on the more complex medical terminology that is used in ICD-10. The WHO noted that countries that offer this foundational knowledge have a much easier time transitioning to the new system.

CMS has stated, even prior to this latest possible delay in the implementation, that training to actually teach coders how to assign codes in the new system is premature. They recommend that coders should not be educated in the actual assignment of ICD-10 codes until six to nine months prior to the implementation. Our “Prep for ICD-10” class does not focus on actual code assignment. Not only is it too early to teach this skill, it would require attendees to buy an expensive copy of the draft codeset in order to participate. We are sensitive to this expense and are following the authoritative recommendation to not train coders how to assign ICD-10 codes at this point.

However, ICD-10 is coming at some point and when the time is right, based on recommendations by those entities in charge of the transition, OASIS Answers will incorporate into our coding education, instruction and reinforcement of knowledge that will make coders better at assigning ICD-9 codes now, while simultaneously preparing them to code in ICD-10.

As with so many other home care challenges, thoughtful and proactive planning to ensure compliance before, during and after a significant transition, like the move the ICD-10, will minimize provider stress and risk.

Upcoming ICD-9 & ICD-10 Coding Workshops in Florida

Click here to view the complete schedule of upcoming HCAF education events.

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