Proposed One Year Delay of ICD-10

As many of you may have heard, yesterday HHS announced a proposed rule that would delay the compliance date of ICD-10 for one year, from October 1, 2013 to October 1, 2014.

While we have stated our opposition to a delay, we are pleased that HHS has issued a proposed date so that people can move forward and properly plan with a new date in effect.

We also applaud HHS for addressing the added costs this delay will cause. They state a 1-year delay would add 10 to 30 percent to the cost—or $1 to 6.4 billion— for entities that have spent or budgeted for the transition. It’s disappointing that those who were properly preparing will incur these penalties, but what’s more of a concern is the message it sends about the ability to procrastinate. While some organizations may think, “Why should we prepare early, we might get penalized,” that’s not a gamble we would want to take.

Despite the fact that groups like the AMA opposed ICD-10 because of it’s financial burden, HHS explains the reason for a delay is to allow ample time between implementation of Version 5010 (now going into effect June 2012), which is needed before ICD-10 can be implemented.

One thing is clear in the HHS proposal. They have no intent to completely kill ICD-10 and move to ICD-11. ICD-10 is coming, albeit a year later than anticipated, and organizations need to prepare.

What now? Organizations will need to re-evaluate their timelines. If you were behind the ball before, now is your chance to get on track. If you were already on track for the 2013 deadline, it doesn’t mean you can do nothing for the next 12 months. Spend the time improving on any weaknesses such as documentation by clinicians and work to cultivate relationships between clinicians and coders. Here are 10 more steps you can take to be properly prepared.

As always, we are here to help make the transition to ICD-10 as easy and pain-free as possible. We’re confident everyone can meet the final compliance date and it will make our healthcare system more efficient and cost effective.

Tell us in the comments, how do you feel about the one year delay?

OIG Finds 20% Of Home Health Claims Coded Improperly, Resulting In $462M In Improper Payment

Some concerning news hit the home health community last week.

The Department of Health and Human Services’ (HHS) Office Inspector General (OIG) released a report that showed home health agencies submitted nearly 22% of claims in error because services were either not medically necessary (2.1%) or were coded improperly (20.2%).

This is the first time OIG has significantly addressed home health’s coding on claims. They stated that one of the factors for this review was the fast rise in Medicare home health spending—84% from $8.5 billion in 2000 to $15.7 billion in 2007—which “leads to concerns about the potential for improper payments due to fraud and abuse.”

More than 10 percent of claims (a value of $278 million) were considered up-coded, and 9.8% of claims (a value of $184 million) were found to be down-coded. This equates to a net loss of $94 million for the 
Medicare system.

While the report did not go into extensive details on scenarios that they found problematic, they did give an example of the frequent inappropriate use of GERD 530.81. We plan to discuss this further in our next blog post.

The results of this report are very significant and should be taken seriously by home health agencies. Whether the error is unintentional or not, agencies can get themselves into a lot trouble. CMS is cracking down and “has begun using technologies and analytic tools to prevent fraudulent payments and identify risky providers and claims.”

On the bright side, just 2% of claims did not show medical necessity. Agencies are doing a great job ensuring the services they provide are medically needed. 

Here at Daymarck, we have a very strict compliance stance. It is our first and foremost priority. We never up-code or use filler codes, and we code every agency the same. We also stay up to date with the constantly changing rules and regulations to ensure our clients are 100% compliant.

Now more than ever it’s critical that you are submitting accurate claims. If you’d like someone to give your agency an audit to see how you are doing, we can help. Contact us to discuss a coding “check up.”

To learn more about our view on compliance, visit here.

Our Response to ICD-10 Delay

The Department of Health and Human Services (HHS) announced on Thursday that they plan to delay ICD-10. With no specifics on what this delay will entail, it’s causing a lot of confusion and speculation about what is to come. We feel it was very irresponsible for HHS and the Obama Administration to make those statements without giving a clear plan. 

As we stated back in November when the AMA began opposing ICD-10, we disagree with a delay. We firmly believe conversion to ICD-10 is long overdue and delaying it will only increase health care costs and the burden on everyone.

We are very disappointed with HHS’ decision, which contradicts everything they have been saying. On CMS’ November 17^th national provider call, representative Pat Brooks said, “This is a firm implementation date, and there will be no delay.” CMS and HHS have been adamant all along that there would not be a delay. In turn, the health care community has spent a lot of time and money investing in new processes and systems. By going back on their statements, they are continuing to lose credibility.

Vendors, as well as publishers, educators, colleges, consultants, and many others, have already spent millions of dollars getting ready for conversion. It has even spurred job creation— for example new positions like ICD-10 Project Manager.  Even health care providers like hospitals and home care agencies have invested significant resources into the transition. With a delay, all of these groups will have to re-work what they've already done and it will cost more money. This added cost for vendors will be pushed down to providers, and then consumers. 

This decision also has a lot of political pressure and motives behind it. CMS’ Acting administrator Marilyn Tavenner made the announcement that they would re-evaluate the timeline at an AMA meeting. It’s important to note Tavenner is currently vying for the official appointment and AMA backed her nomination in November.

We’re also concerned about HHS’ use of the term "compliance" date, suggesting ICD-10 will be implemented per schedule, but providers will have a leeway period where they won't be found in non-compliance. In some instances a leeway period makes sense, for example with the new Face-to-Face requirements, claims were allowed to go through for three months after implementation.  But if this happens with ICD-10, it can be extremely harmful because vendors will have to work in two different sets of codes at once, in turn driving up costs and administrative burden even more.

While we anxiously await HHS’ new plan, we’ll continue our planning with the October 1, 2013 deadline in mind. We suggest no one stop in their preparations and hopefully we will quickly receive a revised plan from HHS.

Our hope is that the delay is brief because the shift to ICD-10 is a big step to improving health care in this country. It will make our healthcare system more efficient and cost effective and improve the level of care that this nation needs.

We're here to make the transition to ICD-10 pain-free and easy for home care agencies. Please contact us anytime to discuss how your organization can have a smooth transition.