ASC (6)

What are providers, payers, suppliers and clearinghouses doing in the wake of the unexpected announcement by the Department of Health & Human Services (HHS) that it plans to delay implementation of the ICD-10 system?

February 16, 2012




ICD-10: What Just Happened?
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Tuesday, Wednesday and Thursday
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As soon as providers and vendors get over the hurdle of the version 5010 implementation, "We’ll see that everyone’s time and attention will turn to I-10. …They’ll be able to focus on the real work of implementation."

That’s what Denise Buenning, director of the administrative simplification group in the Centers for Medicare & Medicaid Services Office of E-Health Standards and Services, stated during the Jan. 31 airing of the live, Talk Ten Tuesday entitled Reality Check: Where are we now—three years later?

ICD-10-CM category L89 codes classify pressure ulcers, also known as bed sores, pressure sores or decubitus ulcers. Pressure ulcers are wounds caused by unrelieved pressure on the skin. These ulcers are localized injuries affecting skin and underlying tissues, representing trauma associated with pressure and also friction, immobility, poor nutrition, hard surfaces and existing scars.

I have been meaning to respond to a lot of articles concerning the ICD-10 conversion and meaningful use in the EHR arena, but I felt it would not necessarily engender any useful outcome. After 40 years in the industry, however, I decided I might have as much of a right as anyone to at least express my opinion, since I was there the day the first PC landed in my department.

Irrespective of the fact that ICD-10 conversion is going to cost the healthcare industry billions of dollars at a time when revenue and patient volumes are shrinking, I am convinced we need to slow down our march toward total automation under meaningful use and ICD-10. Compounding the challenges created by shrinking revenues, government intrusion and oversight of potential areas of fraud or abuse demand more manpower and resources at the provider level in order to monitor and edit claims and documentation – thus raising operational costs.

Recently, for example, hospitals and healthcare providers met the challenge of the new 5010 claim form. It has been devastating to cash flow in innumerable facilities and services in the industry. The software and integrated EHR systems were not ready to handle the new form. Although CMS extended mandatory implementation for 90 days, the cost to the industry already has been very high.

ICD-10 would be beneficial in tracking disease and services throughout the global economy, increasing our ability to zero in on populations with higher incidences of specific conditions and healthcare service issues. However, the direct benefit to the individual patient is minimal, if it exists at all. The cost to our healthcare industry, on the other hand, is astronomical at a time when the economy is in the doldrums and the culture of the healthcare industry is rapidly evolving.

In keeping with that theme, the push to implement EHRs – driven by meaningful use criteria and promises of millions of dollars in reimbursement to providers for meeting the required criteria – is ludicrous in light of the already stressed economy. Having served on the meaningful use task force at our facility, I know we have learned that most current systems are not ready (and will not be ready for some time to come) to optimally handle the documentation required to meet meaningful use requirements. For the most part, current EHR systems are not sophisticated enough to guarantee patient safety and deliver efficient, quality outcomes; bottom line, these systems place the patient at risk for provider error and poorer outcomes.

I applaud all efforts to automate the healthcare delivery system. If done right and thoroughly tested for safety and quality, the efficiencies and return on investment will be immeasurable. But this should not be pushed through just to allow us to say we are “automated” and able to provide health information at the touch of a button! Misdiagnosis, treatment errors and erroneous documentation pose a far-reaching threat to quality healthcare, in my opinion. A sum of $7 million in meaningful use rewards for achieving EHR quality measures and other criteria is not worth the death of, or harm to, one single patient. Without the MU reward potential, many organizations would not be attempting to automate, because a $20 million EHR does not compare to a $20 million rehabilitation center, or new medical laboratory, or new emergency care wing to the hospital.

Well, that is my take on the issue of pushing forward with ICD-10 and meaningful use at this point in U.S. history. I hope we ultimately get to where we want to go, but not at the cost of deaths, maimings or other disastrous outcomes due to systems and processes that are simply not ready to provide for seamless and flawless transfer and dispensation of information to treat patients safely and securely. Although data repositories brimming with gigabytes of health data is a researcher’s nirvana and could allow statisticians to extrapolate theorems and projections light years into the future, the immediate anticipated return on investment in terms of both dollars and patient health is not worth the potential cost.


Phyllis Dreading, RHIT,
Director, Health Information Management


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If you work in an ambulatory surgery center (ASC) and have started to hear about the ICD-10-CM, you are probably wondering if this will affect you. The answer is a resounding YES!  All providers who currently use ICD-9-CM diagnosis codes to bill for services provided will need to transition to ICD-10-CM.

The good news is that ASCs will not have to worry about the procedure portion of ICD-10 (identified as ICD-10-PCS) since most, if not all, surgery centers use CPT codes to bill for procedures performed. The ICD-10-PCS is much more difficult than ICD-10-CM to grasp because coders will need to be proficient in anatomy, physiology and terminology and also will need to understand how operative procedures are performed.

Before we begin to explore what ASCs should do to prepare for the implementation of ICD-10-CM, which is now set for October 1, 2013, let’s set one thing straight. Many of you have probably heard others say that the Centers for Medicare & Medicaid Services will delay implementation because the change will be too costly.

Don’t be fooled by this kind of wishful thinking because CMS’s plans and processes are rapidly moving for the October 2013 implementation date. Surgery centers can ease the pain of implementation by being prepared.

Preparing for the Transition

All providers, including ASCs, must set aside a budget for the implementation of ICD-10-CM as coders will need to be trained and software will need to be updated or purchased. For example, super bills or paper charge forms will need to be revised with the ICD-10-CM codes replacing the current ICD-9-CM codes.

This change may spur many surgery centers to move towards electronic medical records/super bills since ICD-10-CM has many more specific codes than the current ICD-9-CM coding system.  Because of this fact, paper forms will become too cumbersome.

At this point in the implementation, ASCs also should be reviewing all of their software programs in which ICD-9-CM codes are entered and begin contacting their vendors to determine their ICD-10-CM implementation schedule.  If the software vendor is not in the process of implementing a transition schedule, dialogue should take place to determine their transition program.  ASC managers may need to determine if they need to look elsewhere for software that will be ready for ICD-10-CM.

As we get closer to the implementation date, surgery centers will need to analyze their payers’ contracts and contact individual payers to determine if they will require ICD-10-CM for diagnosis and CPT for the procedures or will require use of ICD-10-PCS for procedures. As many of the surgery centers bill CPT to payers for the procedures/services performed, there are a few that also require the ICD-9-CM procedure codes.

Education is Key

Next, conduct an educational program for the physicians who practice in the surgery center to inform them about the new ICD-10-CM system and its implementation timeline. Also educate them about the need for clear, comprehensive, concise documentation. Vague or ambiguous documentation will create problems when assigning the ICD-10-CM codes.

Physicians are not the only ones who will need to be educated. Coding and billing staff in the surgery centers will need a strong foundation in anatomy, physiology and terminology. Those who are deficient in these areas should receive training (either initial or a refresher) in the areas of A&P and terminology.

The American Health Information Management Association (AHIMA) recommends that actual ICD-10-CM training of coding and billing staff begin late in 2012 or early 2013. Conducting training for staff any earlier than this is futile because they will not have an opportunity to use what they have learned and may not retain the information. The only exception to this advice would be for those coders and billers who will become certified trainers for your organization.

AHIMA estimates that each coder or biller will need approximately 40 hours of ICD-10-CM training to understand and be able to use the system.  With this kind of extensive training required, the surgery center will need to investigate how they will get their current cases coded and billed while their staff is being trained in ICD-10-CM.  Many facilities may elect to use a back-log coding company to cover for the staff while they are training.

Plan to Go Beyond the Surface

The above are just a few steps that surgery centers should be taking at this point in order to be prepared for the ICD-10-CM implementation. Keeping your head buried in the sand and saying that you have plenty of time to worry about ICD-10-CM can potentially affect your practice and its cash flow. Be proactive and prepared and your implementation should flow smoothly.

About the Author

Peggy Hapner, RHIA, CCS, CASCC, is a MedLearn consulting services manager with nearly 25 years of experience in health information management, coding, teaching, data quality and operations. She is MedLearn’s technical expert for hospital outpatient HIM services.

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