Six months to go: What you need to do
Your checklist should include checking with vendors and payers, beta testing and training staff.
By René Luthe, Senior Associate Editor
It’s a safe bet you don’t want to hear this right now, but ICD-10 will be the law of the land in about six months. Doubtless you’ve been informed numerous times — by the Academy, the American Society of Cataract and Refractive Surgeons, the American Medical Association, your practice administrator, the media — that a lot of preparation is required ASAP to maintain cash flow and avoid rejected claims come October 1.
Human nature being what it is, however, you may not have quite got around to doing much yet. Here, those familiar with the requirements of ICD-10 help you prioritize where you need to start — if not yesterday, then today.
START WITH I.T.
Leave no system behind
Inventory the systems in your practice that ICD-10 will affect, advises Robert Tennant, senior policy advisor at Medical Group Management Association (MGMA). Obviously this would include the billing system and practice management software, but the EHR must also be updated or, barring that, replaced. Practices that perform clinical trials must also check the relevant software — “Anything that potentially might use a diagnosis code,” Mr. Tennant says.
As basic as it may sound, Mr. Tennant says the MGMA recommends its members create a spreadsheet or a table, or even handwritten list of these systems, vendor contact information, internal staff assigned to oversee the upgrade or replacement, expected date for the change and resolution.
Have you spoken with your vendor lately?
Michael X. Repka, MD, medical director for governmental affairs for the AAO, suggests clinicians contact their EHR vendors as soon as possible. Consultant Patricia M. Morris, COE, of New York agrees, noting that while some software companies are readying for ICD-10, others are not. You don’t want to find out in August your vendor is in the latter category.
Mr. Tennant recommends your communication include a certified letter to the vendor. He says questions should include the following:
• Will you provide an upgrade to the version of the software I own?
• If the answer is no, will you offer a replacement software?
• When will the upgrade or replacement take place?
• How long will implementation take?
• How will you search for the new codes?
• Will the upgrade require hardware changes? Faster processor speed or more RAM?
• Will the software permit the use of dual coding? “Will it be able to use both ICD-9 and ICD-10, in case some of your trading partners are not ready, such as a health plan, or should the government institute a dual coding period,” Mr. Tennant asks.
• What will be the total cost to the practice, including any training?
There’s reason to get answers to these questions as soon as possible, according to Mr. Tennant. While the EHR and practice management software vendors MGMA interviewed were all “gleefully proud” that they had devised an ICD-10 solution, “Every single one we’ve talked to said they are only producing their upgrade for the latest version of their software.”
Beta-testing due now
According to Jeff Grant, president and founder, HCMA Inc., EHR vendors should now at least be at the point where they are conducting some beta testing. “They may not have a version released that supports both ICD-10 and ICD-9 that’s ready for general release, but they should at least have something they are putting into some of their live sites to make sure things are working correctly,” he explains.
Further, never assume your vendor can get to you in what you consider a timely manner. “Even if you realize you need an upgrade or replacement software, the vendor may not have the bandwidth to get to you by October 1,” Mr. Tennant notes.
Need a crash course in ICD-10?
Your first lesson in the ICD-10 crash course should be on the CMS website, Mr. Tennant says. “All roads start there in terms of resources.” The site offers plenty of information with more to come, possibly specialty-specific. It’s also free, he notes. “There’s even a nice how-to guide aimed at smaller practices.” Other sources are available, too.
Implementation time lines and transition checklists for both large and small practices, are available at www.cms.gov/Medicare/Coding/ICD-10ImplementationTimelines.html (accessible through the Ophthalmology Management website).
CMS’s Quick Reference Guides, also on the agency’s website, are helpful, as is the guide on Stage 2 for Meaningful Use Ms. Morris notes.
The MGMA website, www.mgma.org, also offers free materials if the practice administrator is an MGMA member. These include a three-hour webinar on ICD-10 and an implementation guide.
Regulatory updates by the Academy and ASCRS are helpful, and Ms. Morris urges ophthalmologists to use them. “Washington Watch and all those tools are really important to stay ahead. You may not always go to the CMS site, and you may not read every notice you get from CMS,” she says. “But the Academy and ASCRS do a good job of keeping those things that are going to cost us money in the long run in front of us.”
For staff-training resources, JCAHPO CEO Lynn Anderson, PhD, recommends the Academy (“One of the best training programs for ICD-10.”), JCAHPO’s online courses and webinars, and ActionEd.org (JCAHPO’s online source for continuing ophthalmic education). “We hold three Webinars a month and the topics rotate; we’ve had some ICD-10 and we’ll have more coming up,” Ms. Anderson says. The organization will be offering a technician program at the ASCRS meeting next month in Boston.
Apps for smart phones. Those with iPhones and iPads may want to avail themselves of two free apps. STAT ICD-10 and ICD-10 Lite provide an opportunity to get the feel for ICD-10, Mr. Grant says, though they don’t offer the level of detail that an ICD-10 reference book would. “They do a pretty good job and given the number of people who now have smart devices, a lot of people can take advantage of them,” he says.
The vendor may give you a date sometime in early 2015 — or not so early 2015. “Not only are vendors trying to develop an ICD-10 solution, it’s also the year that Stage 2 of Meaningful Use goes into effect, so many are upgrading for that as well,” he explains. “There’s huge potential for a funnel effect, with all these practices trying to get through this little opening.”
THE INSURERS
Don’t overlook payers
But vendors are not the only ones practices should quiz on ICD-10 readiness. Mr. Grant points out that while EHR vendors can conduct tests to ensure their software handles the new coding system, they cannot test with the payer. “And the payers are the ones I’m most worried about,” he says.
Practices would do well to contact their primary payers to determine where they stand with ICD-10, Mr. Grant advises. First stop should be the insurer’s website to check for statements on the subject. “If you find nothing, that would make me a little nervous,” he says. Ideally, the payer should tell you it is already testing systems and processing dummy claims with the new coding.
INTERNAL ACTIONS
Evaluating provider preparedness
After nailing things down with the relevant vendors and payers, Mr. Tennant advises practices next turn their attention to clinical documentation improvement (CDI). “MGMA recommends the practice take one of three steps to ascertain whether their ophthalmologists are documenting the clinical encounter to the level of specificity needed to assign an appropriate ICD-10 code,” he says. The three approaches are:
• Take a selection of claims a payer has already processed successfully using ICD-9 codes and see if you can assign an appropriate ICD-10 code to them. “You are looking back at what you documented and seeing if you, for example, put in the laterality — left eye or right eye?” he says. “Better find out now that some of your ophthalmologists are not doing a very good job at that than find out next fall.”
• Now try it in reverse. While you are developing your claim, before you submit it, assign an ICD-10 code as well as an ICD-9. If you cannot designate a specific ICD-10 code, that’s a signal that the clinicians need additional documentation training.
• Employ a vendor, or a consultant, to take these steps: review your claims, look at what you’ve assigned as an ICD-10 code, and determine if the documentation is sufficient. Larger groups can take this approach.
Do you outsource?
As for practices that outsource to a professional coder, Mr. Tennant warns not to assume those people will be qualified for ICD-10. Some coders he has spoken with claim they will retire rather than go to the trouble of learning the new codes. If that’s the case with your coder, you need to find out as soon as possible.
Change of form
Practices have two ways to submit a claim using an ICD-10 code, Mr. Tennant notes: an electronic form called the HIPAA Version 5010, or a paper form, known as the CMS 1500 form. “Adding to the challenge smaller practices face, the paper form also changed with ICD-10,” he says.
COURTESY: MODERNIZING MEDICINE
Mr. Tennant was a member of the group that developed the new 1500 form, National Uniform Claim Committee. It’s available free on the group’s website, NUCC.org. “Medicare has announced that they will only accept the new 1500 form after April 1,” Mr. Tennant says. Commercial plans are expected to adopt the same date.
“You as a practice need to ask your EHR vendor if they have updated their systems to accommodate a 1500 form, because in many cases the practice embeds a 1500 form in its software; it’s like a pdf form that you fill out. That system will have to change to accommodate this new 1500 form,” he explains.
“There is already a lack of qualified coders with ICD-9 — the ones who are qualified for ICD-10 will be worth their weight in gold,” Mr. Tennant says. “So be very diligent in determining whether the person who does your coding will be ready in October.”
START TRAINING
Re-education required
But while you and your practice administrator and IT team are busy evaluating the practice areas ICD-10 will impact and whether you have the necessary software, don’t forget you will need some training yourself. To perform well in the CDI, one needs to pursue some study beforehand, Mr. Tennant advises.
Mr. Grant agrees. “I’ll ask people, ‘Have you ever seen an ICD-10 code?’ And they answer, ‘Nope!’ Well, it would be nice to start looking at the format,” he says. Doctors could ask themselves what are the codes they routinely use and investigate how to use them under the new system.
Ms. Morris notes ICD-10 demands doctors not only identify the diagnosis, but also factors such as disease severity and cause. “Physicians are not going to be able to fully rely on their software companies, billers and techs to implement this practice-wide as in the past — physicians will have to engage,” she says.
As for staff
Not that physicians are the only ones who must get a handle on ICD-10. Mr. Grant believes it is essential to begin training staff as soon as possible. Coders will need thorough training in the new system, Mr. Tennant notes, and to ensure that they don’t forget by October what they learned months earlier, periodic exercises may be in order.
Technicians, too, will need in-depth training. Lynn Anderson, PhD, CEO of the Joint Commission on Allied Health Personnel in Ophthalmology , maintains the partnership of technician and physician is key to successful implementation of ICD-10. Having multiple employees understand what the new system requires increases the likelihood that claims are coded correctly and paid promptly.
And putting off training could mean your staff will be behind on October 1, because there is so much to learn. “I don’t think you can start too early and I don’t think you can train enough, because it’s a big transition,” Ms. Anderson says.
How much is enough?
So how much effort will you need to devote to learning ICD-10? Ms. Morris advocates taking a course, but recognizes many physicians don’t have the time. Hitting the CMS website for the agency’s free materials is less demanding and gets a toe into the new coding waters.
The Academy offers a teaching module and an eye-care-specific reference book, so ophthalmologists don’t have to waste time perusing the whole ICD-10 manual, with its 69,000 codes. ASCRS and MGMA offer materials to their members as well.
However you learn the material, start putting what you learn into practice as soon as you can, even if it’s just an item or two. “If they start implementing it now, even if it’s piecemeal, they will get the hang of it,” Ms. Morris says. “Even if they start doing only one or two encounters a day, they can build up to three and four a day. But just like anything else, they need to create a new habit.” OM