ICD 10 Conversion

ICD-10 compliance means that a HIPAA-covered entity uses ICD-10 codes for health care services provided on or after the Conversion Date. ICD-9 diagnosis and inpatient procedure codes cannot be used for services provided on or after this date. Everyone covered by HIPAA must be ICD-10 compliant starting on the Conversion Date.

No. The transition to ICD-10 does not affect CPT coding for outpatient procedures and physician services. Like ICD-9 procedure codes, ICD-10-PCS codes are for hospital inpatient procedures only.

Everyone covered by HIPAA must use ICD-10 starting on the Conversion Date. This includes health care providers and payers who do not deal with Medicare claims. Organizations that are not covered by HIPAA, but use ICD-9 codes should be aware that their coding may become obsolete if they do not transition to ICD-10.

Claims for all health care services and hospital inpatient procedures performed on or after the Conversion Date, must use ICD-10 diagnosis and inpatient procedure codes. (This does not apply to CPT coding for outpatient procedures.) Claims that do not use ICD-10 diagnosis and inpatient procedure codes cannot be processed. It is important to note, however, that claims for services provided before the Conversion Date, must use ICD-9 diagnosis and inpatient procedure codes.

Practice management systems must be able to accommodate both ICD-9 and ICD-10 codes until all claims and other transactions for services before the Conversion Date, have been processed and completed. Promptly processing ICD-9 transactions as the transition date nears will help limit disruptions and will limit the time frame when dual code sets need to be used.

ICD-10 codes are completely different from ICD-9 codes. Currently, ICD-9 codes are mostly numeric and have 3 to 5 digits. ICD-10 codes are alphanumeric and contain 3 to 7 characters. ICD-10 is more robust and descriptive with “one-to-many” matches to ICD-9 in some instances. Like ICD-9 codes are now, ICD-10 codes will be updated every year. ICD-9 codes will not continue to be updated after the Conversion Date.

The health care industry is making the transition from ICD-9 to ICD-10 because: ICD-9 codes provide limited data about patients’ medical conditions and hospital inpatient procedures. ICD-9 is 30 years old, it has outdated and obsolete terms, and is inconsistent with current medical practices. Also, the structure of ICD-9 limits the number of new codes that can be created, and many ICD-9 categories are full.

 ICD-10 codes allow for greater specificity and exactness in describing a patient’s diagnosis and in classifying inpatient procedures. ICD-10 will also accommodate newly developed diagnoses and procedures, innovations in technology and treatment, performance-based payment systems, and more accurate billing. ICD-10 coding will make the billing process more streamlined and efficient, and this will also allow for more precise methods of detecting fraud.

For providers who have not yet started to transition to ICD-10, below are action steps to take now. Some of these activities, such as establishing a transition team and communicating to internal staff, might not be necessary for small practices where one or two people would be handling the transition activities.

• Establish a transition team or ICD-10 project coordinator, depending on the size of your organization, to lead the transition to ICD-10 for your organization. Develop a plan for making the transition to ICD-10; include a timeline that identifies tasks to be completed and crucial milestones/relationships, task owners, resources needed, and estimated start and end dates.
• Determine how ICD-10 will affect your organization. Start by reviewing how and where you currently use ICD-9 codes. Make sure you have accounted for the use of ICD-9 in authorizations/pre-certifications, physician orders, medical records, super bills/encounter forms, practice management and billing systems, and coding manuals.
• Review how ICD-10 will affect clinical documentation requirements and electronic health record (EHR) templates.
• Communicate the plan, timeline, and new system changes and processes to your organization, and ensure that leadership and staff understand the extent of the effort the ICD-10 transition requires.
• Secure a budget that accounts for software upgrades/software license costs, hardware procurement, staff training costs, revision of forms, work flow changes during and after implementation, and risk mitigation.
• Talk with your payers, billing and IT staff, and practice management system and/or EHR vendors about their preparations and readiness.
• Coordinate your ICD-10 transition plans among your trading partners and evaluate contracts with payers and vendors for policy revisions, testing timelines, and costs related to the ICD-10 transition. Talk to your trading partners about testing, and create a testing plan.

The following are steps you can take to ensure a smooth transition to ICD-10:

• Have a transition plan in place and make sure it documents the steps being followed and the dates that milestones will be achieved to comply with ICD-10 requirements
• Include vendor tasks in your plan and timeline, and make sure to communicate with your practice management system and/or EHR vendors regularly about ICD-10
• Establish an emergency fund to cover unexpected costs and possible reimbursement delays

Software vendors should be working with customers to install and test ICD-10-ready products. Take a proactive role in assisting with the transition and partner with your customers so that they can get their claims paid and avoid any interruption to their business processes. Products and services will be obsolete if steps are not taken to prepare.

Clearinghouses and third-party billing services should be coordinating with vendors to ensure software products are up-to-date, and should be ready to test claims and other transactions using ICD-10 with providers and payers. Please note, clearinghouse services do not convert ICD-9 to ICD-10 for providers and payers. CMS has resources to help vendors, clearinghouses, and third-party billing services and their customers prepare for a smooth transition to ICD-10. 

• Identifying how ICD-10 will affect your organization
• Developing a plan for implementing ICD-10 and creating a timeline of activities
• Working with vendors on new software/systems to accommodate ICD-10
• Coordinating with vendors, payers, and other business partners about ICD-10, especially about testing transactions and processes that use ICD-10

The American Health Information Management Association (AHIMA) recommends training begin no more than six to nine months before the Conversion Date, compliance deadline. Training needs will vary for different organizations, but it is projected to take 16 hours for outpatient coders and 50 hours for inpatient coders.

Coders in physician practices will need to learn ICD-10 diagnosis coding only, while hospital coders will need to learn both ICD-10 diagnosis and ICD-10 inpatient procedure coding. Take into account that ICD-10 coding training may be integrated into the CEUs that certified coders must take to maintain their credentials.

In addition, some high-level ICD-10 training will be required earlier so that staff can conduct testing in 2013. This includes training to learn the new ICD-10 systems and understand how the structure and granularity of the ICD-10 codes will affect clinical documentation.

• ICD-10: A Guide for Small and Medium Practices
• ICD-10: A Guide for Large Practices
• Transition to ICD-10: Getting Started

Visit the CMS ICD-10 website and sign up for the CMS ICD-10 Email Updates to receive the latest news and resources on ICD-10. Also, stay informed by following CMS on Twitter.