By promising not to deny Part B claims with valid, but incorrect, ICD-10-CM codes for the first 12 months after ICD-10 implementation, the Centers for Medicare and Medicaid Services (CMS) paved the way for the American Medical Association to drop its insistence that implementation be delayed beyond this fall. In fact, the AMA and CMS have now joined together to help physicians and other providers, especially those in small practices, adapt to the new coding system.
In a joint June press release, CMS and AMA announced their plans to offer online and on-site training, and instructional articles to help providers transition to ICD-10. CMS’s website “Road to 10” is a central site where physicians can get a wide range of information and access key links. The agency has also published brief guidance with questions and answers about what claims will and will not be denied, and has created an ombudsman who will handle transition issues. The AMA will offer transition resources on its AMA Wire web page.
The CMS guidance clarifies the 12-month leniency period: Medicare will not deny Part B claims based solely on errors in the specificity of ICD-10 diagnosis codes as long as there is a valid code on the claim from the correct code family. CMS emphasizes that a valid ICD-10 code is absolutely required. It is not enough to have a general code from the right family but not all the characters required. No ICD-9-CM codes will be accepted after October 1, 2015.
As for quality reporting, CMS explains that, for program year 2015, practices will not be penalized as far as quality measures are concerned as long as physician and other provider claims contain valid ICD-10 codes from the correct family of codes. The agency states that eligible providers (EPs) also will not be penalized if CMS has trouble calculating the quality scores for the Physician Quality Reporting System, value-based payment modifier, or meaningful use because of the ICD-10 transition.
If Medicare contractors are unable to process payments within time limits because of the transition, physicians and suppliers can apply for advance payment. This is a partial payment that must be returned once the contractor clears the logjam of claims. Note that CMS does not make advance payments to practices that are unable to submit claims because of the switch-over to the new coding system.
Practices running into transition problems will be able to submit their issues to an ombudsman, who will be part of a communication and collaboration center CMS sets up for monitoring ICD-10 implementation. The ombudsman will help sift through and triage issues and work closely with representatives in CMS regional offices to solve problems. CMS will release information on how to submit issues to the ombudsman closer to the implementation date of ICD-10.
Aside from these initiatives to ease the transition to ICD-10, CMS will:
- Complete the final Medicare end-to-end testing for providers
- Offer providers Medicare acknowledgment testing through September 30
- Provide in-person training for small practices through “Road to 10”
- Host an MLN Connects national provider call on August 27