Practice Makes Perfect: ICD-10 delay allows time for clinical documentation improvement

In June, the Medical Group Management Association released the results of a questionnaire that ranked members' most pressing practice-management challenges. In this edition of “Practice Makes Perfect,” we'll tackle No. 1 on that list: preparing for the transition to ICD-10 diagnostic coding.

In DATA, the CMS announced that the new implementation deadline for the International Classification of Diseases, Tenth Revision (ICD-10) will be Oct. 1, 2015. The delay, included in the Protecting Access to Medicare Act of 2014, is the most recent of several extensions for physician practices to adopt the diagnosis component of this new code set. After the revised date, claims will need to be coded with one of the estimated 69,000 codes, up from the current 13,000 in ICD-9.

With the additional year's delay, practices are justifiably concerned about investing significant organizational resources in a mandate that has now been postponed several times. One approach that practices can take is to identify actions that require minimal financial outlay, yet could benefit the organization's ICD-10 efforts. The additional 12 months provides an opportunity to engage in clinical documentation improvement, or CDI, a key action item in a successful transition to ICD-10.

CDI can provide a number of benefits for practices beyond simply getting ready for ICD-10. More complete documentation of the clinical encounter can enhance billing accuracy, guard against payment audits, augment a patient's medical record, and improve transitions of care for patients by giving downstream providers a more complete record.

Accurate documentation of the patient encounter is critical to outpatient billing. Coders can only code from the information provided in the medical record. Should the record not contain the necessary elements, coders may not be able to identify the most appropriate code. ICD-10 is far more granular than the current code set and includes elements that may not be captured now by clinicians, such as laterality, encounter type (initial, subsequent, sequel, routine healing, delayed healing), anatomic details, severity and disease relationships.

If the patient encounter documentation is not complete, the coding staff may need to “chase” the clinician for the appropriate information. This, in turn, can delay claim submission. In situations where there is a significant time lapse between the patient encounter and the coding of the claim, it might be next to impossible for the clinician to accurately recall the relevant details required to assign a more granular ICD-10 code.

Medical practices' CDI efforts can include a number of tests that can be an effective barometer of how the organization will fare after the compliance date. These tests can include:

• Identifying your top 25 or so most frequently billed codes using ICD-9 principal-diagnosis codes. Study previous successfully adjudicated claims, and map those claims to ICD-10 codes. Determine whether the records contain the necessary clinical information to support an appropriate ICD-10 diagnosis code. Following this test, practices can work with clinicians on weak or incomplete documentation.
• Aligning the top 25 or so ICD-9 diagnosis codes, practice “dual coding” a selection of live claims by mapping them to ICD-10 codes. Audit to determine whether the records contain the necessary information to support the appropriate ICD-10 diagnosis code.
• Taking any opportunity to test with your software vendor, clearinghouse or health plans. Some of these trading partners may offer a variety of testing opportunities that could be valuable in determining your overall ICD-10 readiness level.

With Congress mandating a minimum of one additional year for the healthcare industry to move forward with ICD-10, CDI is an opportunity to take a low-cost, high-impact step toward preparing for the new code set.