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May 2, 2011

Billy's World: CMS Cites “Myths and Facts,” But Which are Which?

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Several times during the last couple of years, CMS has published various articles telling us why ICD-10 is so good for us, reminding us that it’s not optional, and addressing “myths and facts” in its role as “Enforcer of the HIPAA Transaction Rule.” But let’s be honest: they haven’t addressed all the myths and facts, and frankly some of their “facts” read more like myths. So let’s take a few moments to consider some of the true “facts” of ICD-10 and opine – item by item – as to their ultimate veracity.

•    CMS says Oct. 1, 2013 is the scheduled changeover date from ICD-9 to ICD-10, adding that there will be no extensions of that date.

•    This is probably true, because this change isn’t being driven by a “Final Rule” or any other recent publication from CMS. “It’s HIPAA, Baby!”, and we all know how helpful HIPAA has been to the provider and payer communities.

•    Non-covered entities – those not subject to HIPAA or HITECH – don’t need to convert to ICD-10-CM or PCS.

•    CMS likes to pretend this is a myth, but it’s actually true. Examples of these entities are workers’ compensation systems and auto insurance companies, most of which use ICD-9. Under current law they cannot be compelled to convert to ICD-10, but let’s be honest,  not converting would be like taking a Model A to the Indy 500 – you can make it around the track, but you won’t be first across the finish line. In its magnanimous wisdom, CMS has declined to help non-HIPAA entities convert to ICD-10 and instead will “encourage” (their word, not mine) them to make the conversion. This very much looks like an opportunity for any number of consulting firms!

•    CMS – the Centers for Medicare & Medicaid Services – says it will work with the various state entitlement programs to “ensure that ICD-10-CM/PCS is implemented on time.”

•    Yes, of course: just like CMS banned Level III HCPCS (those beginning with W, X, Y and Z) back in 2006, but MediCal and certain other payers still use them.

•    Let’s be honest: How is CMS really going to fulfill this pledge in the case of a state program that’s having trouble meeting the deadline? Surely they could “de-certify” the program, but that presumably would last about a month.

•    CMS: “The use of ICD-10-CM/PCS is not predicated on the use of electronic hardware and software.”

•    This is presented as “fact,” but it’s really more of a myth. Here are your options:

•    Buy a hardware/software solution;
•    Hire three times as many coders as ICD-9 required; or (and I really like this one)
•    Contract with a third party to do your coding (I can virtually guarantee the third party will have a hardware/software solution).

•    And yes, you can go the “manual” route, if you actually believe the CMS company line, but if you do you’re likely to experience:

•    Poorer coding;
•    Lower payments;
•    Slower payments;
•    Higher error rates (and higher denial rates);
•    Increased personnel costs; and
•    Decreased comparability with your competition

•    Remember, if you reject automation, you take your chances.


 

•    Another supposed “myth:” Unnecessarily detailed medical record documentation will be required   when ICD-10-CM/PCS is implemented. CMS still says “nonspecific codes are still available for use.”

•    Just don’t expect to get paid for them.
•    And it’s only a matter of time before they are disallowed by groupers (especially MS-DRGs).

•    Wait, lest you think I’m 100 percent negative, here’s a good one, an actual myth: The GEMs are intended to facilitate the process of coding medical records.

•    (Drum roll) Isn’t that ridiculous? (Cymbal shot).
•    Since ICD-9 to ICD-10 generally is a “one-to-many” crosswalk, GEM simply cannot be used to code. So if you have an automated ICD-9 system and you think you can save a buck by using GEM to convert coding to ICD-10, you really need to reestablish your grip on reality.
•    GEM is intended to be used only for converting the following databases:

•    Payment systems;
•    Payment and coverage edits;
•    Risk adjustment logic;
•    Quality measures; and
•    Certain research applications in which trending crosses Oct. 1, 2013.

Aren’t fact/myth lists great fun?
To close out this month, here are some real facts:

•    ICD-10-CM/PCS is better than ICD-9, if for no other reason than the fact that it is some 30 years newer.
•    ICD-10 is remarkably more flexible and will provide much better information for researchers and statisticians.
•    ICD-10 implementation is costly; there are no “bargains” and there are no shortcuts. If you have not already enlisted the full support and assistance of all your vendors that manage coding or coded records, you already are behind the 8-ball.
•    There are no shortcuts to ICD-10 compliance.
•    You must automate to implement and manage ICD-10 successfully. If you have an automated ICD-9 system, you’re more than halfway home.

Until next time…

About the Author

Billy K. Richburg, M.S., FHFMA is HFMA-Certified in Accounting and Finance, Patient Accounting and Managed Care. Bill graduated from the U. of Alaska, Anchorage and earned his M.S. in Health Care Administration from Trinity University, San Antonio, TX. Over a career spanning more than 40 years, Bill has held positions including CEO, COO, CFO, and CIO in hospitals ranging from 75 beds to over 300 beds, and in home health agencies, DME stores, and a home infusion company. Bill is a Board Member of the Lone Star Chapter, HFMA, and is Director of Government Programs for the Revenue Cycle Technologies business segment of MedAssets, Inc. His office is in Plano, Texas.

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Read 45 times Updated on September 23, 2013
Billy Richburg, M.S., FHFMA

Billy K. Richburg, MS, FHFMA is HFMA-Certified in Accounting and Finance, Patient Accounting and Managed Care. Bill graduated from the University of Alaska, Anchorage and earned his MS in Health Care Administration from Trinity University, San Antonio, Tex. Over a career spanning more than 40 years, Bill has held positions including CEO, COO, CFO, and CIO in hospitals ranging from 75 beds to over 300 beds, and in home health agencies, DME stores, and a home infusion company. Bill is a Board Member of the Lone Star Chapter, HFMA, and is Senior Director of Government Programs for the Revenue Cycle Technologies business segment of MedAssets, Inc. His office is in Plano, Texas.

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