By most accounts—but not all—the thrice-delayed rollout of the ICD-10 family of diagnostic and procedural codes went smoothly.
But one expert says there's at least one problem with a code for a diagnostic imaging procedure that could take more than a year to clear up.
In Holly Louie's recent column in the ICD-10 Monitor headlined “Dear doctor: We don't care if you don't get paid promptly,” she takes a bite out of the CMS. She says the federal agency is seemingly indifferent to a mistake they made that's affecting some radiologists.
Louie is president of the Healthcare Billing and Management Association, a Laguna Beach, Calif.-based trade group for medical billing companies. She also serves as the HBMA's ICD-10 committee chair and kept a wary eye on progress made in the runup to the Oct. 1, 2015 launch of the complex new coding system.
Louie wrote that on Feb. 5, 2015, the CMS issued a national coverage determination, or NCD, approving Medicare payment of some lung cancer screening using low-dose computed tomography, or LDCT. The first problem, she said, was the CMS initially didn't issue any codes or instructions on how to bill for the procedure.
“In spite of pressure from numerous organizations, the HCPCS code was not released until the 2016 fee schedule was published in the final quarter of 2015,” Louie wrote, referring to the Healthcare Common Procedure Coding System. Providers could begin billing the code on Jan. 1.
“It was bad enough to wait almost a full year to bill for all the legitimate, medically necessary services provided to Medicare beneficiaries,” she wrote, “but the other shoe was about to drop.”
In October, when the covered diagnosis codes in ICD-9 (for LDCTs before Oct. 1) and ICD-10 (for those after) were published, “the CMS had completely omitted the diagnosis codes for current smokers,” she said.
Louie has been communicating with the CMS for over a week and said the agency has promised a plan that will explain how and when corrections will be made.
I sent a copy of Louie's column to the CMS on Feb. 24. So far, I haven't had any better luck getting answers out of them than Louie. I spoke with Louie again Friday, and still had no word from the CMS.
Because NCDs are only updated quarterly and because the CMS already was working on the quarterly updates well into 2016, the earliest a correction for claims can be made is in the July 2016 publication, possibly to be implemented in October.
“Ladies and gentlemen, that is one full year plus either five or eight months before any correct adjudication will begin,” Louie said.
Louie, the compliance officer for Practice Management, a billing company in Boise, Idaho, said in a telephone interview that the problem of forgotten codes isn't isolated to these specific CT scans for smokers.
“I had another client who says she's closing their doors on PET scans,” Louie said. “It's the same type of thing. The NCD didn't include all the codes they should have.”
Louie wonders if the headache will end there. “Will claims need to be resubmitted or will they be reprocessed? There will need to be overrides for timely filing and other operational realities. Will the providers also have to bear that burden?” she asked.
It was ironic that the same day I spoke with Louie, the CMS issued a statement from acting Administrator Andy Slavitt who touted the success of the ICD-10 transition. He said 4.6 million claims were submitted a day and claims rejection and denial rates were coming in at percentages lower than what the CMS described as their “historic baseline.”
And in fact, healthcare leaders who responded to the 26th annual Modern Healthcare Survey of Executive Opinions on Key Health IT Issues generally saw it the same way.
Nearly half (47%) reported that the ICD-10 conversion “Posed no major problems,” while another 43% found it “Went smoothly, but caused minor problems,” 6% thought it “Was difficult, but is now running smoothly,” while for just 4% (including, perhaps, some radiologists?) the switch to ICD-10 “Continues to present problems for my organization.”
Slavitt thanked a number of medical and professional groups for their “close partnerships” in rolling out ICD-10, including the American Medical Association and the American Hospital Association, but not Louie's billing association. One of the lessons learned from the experience, he wrote, was to “be responsive.”
“In the first month of implementation, we received approximately 1,000 inquiries and responded to 100 percent of them within three business days,” Slavitt said. “We will never achieve perfection, but we will be visible and hold ourselves accountable for solving problems.”
