November 14, 2016

Déjà Vu All Over Again

With more than a full year under ICD-10, it seems it is reasonable to expect local coverage determinations (LCD) to be current and correct. After all, everyone in the industry knew there were errors and omissions in some national and local policies.

Many had already been pointed out. And yes, some have been corrected. The expectation was that contractors and commercial payers would take the initiative to review all their publications and make necessary corrections. Not only has that not been done universally, but it appears more errors have arisen in the October 2016 updates.

It also appears the onus is on providers and their representatives to find the errors, notify the contractor of the problem through a formal LCD reconsideration process, and wait for a response to the request to learn whether corrections will be made and if they will be retroactive. In fact, one contractor explicitly stated they would not review their policies unless an error was pointed out through the reconsideration process.

Just a few examples of LCD issues include: Coverage for the initial and subsequent encounters but no sequela codes; the entire category of collapsed thoracic vertebra was omitted; no pregnancy-related respiratory diagnoses; the entire category of displacement of bone devices, implants, and grafts was omitted; cardiac pacemaker covered services omit certain parts of the pacemaker; October 2016 codes with expanded descriptions were completely deleted when the “parent” code was no longer valid—and the list goes on.

In reality, providers and their representatives may not immediately identify key omissions or errors for myriad reasons. They may provide a new service or see a new and different patient population; a third-party revenue cycle management company may begin coding and billing for a new client specialty; the specific disease, disorder, sign or symptoms may not have been documented in past cases; the ICD-10-CM Official Guidelines for Coding and Reporting FY 2017 have added or modified coding instructions; clinical documentation improvement changes historical coding; etc.

Based on some industry reports over the last year, these issues raise the concerns of reporting accuracy. Will less or inaccurate codes be designated when the correct codes are not covered due to policy diagnoses errors and omissions?

While providers certainly must take responsibility for evaluating coding-related issues and denials and address them as necessary, the contractors and commercial payors also have an obligation to accurately update and monitor their policies for errors, oversights, mistakes, and omissions. For the contractors and payers to place the onus on the providers not only to find the issues, but to request reconsideration seems to be shifting what is a clear responsibility to someone else.

It is disconcerting that providers are expected to know and comply with every law, rule, policy, and guideline or risk potentially very punitive results, but the same high standard does not appear to be required of the contractors and payers.

With rare exception, providers are doing their best to provide quality, cost-effective patient care while being inundated in operational and regulatory requirements. Asking them to perform free quality assurance for contractors and payors is unreasonable.

Let’s place the accountability and responsibility where it really belongs.
Holly Louie, RN, BSN, CHBME

Holly Louie is the compliance officer for Practice Management Inc., a multi-specialty billing company in Boise, Idaho. Holly was the 2016 president of the Healthcare Business and Management Association (HBMA) and previously chaired the ICD-10 Committee. Holly is also a national healthcare consultant and testifying expert on matters related to physician coding, billing, and regulatory compliance. She has previously held compliance officer positions in local and international billing companies. Holly is a member of the ICD10monitor editor board and a popular guest on Talk Ten Tuesdays.

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