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HBMA: When It Comes to ICD-10, Don’t Repeat 5010 Mistakes

Because of its significant role in revenue cycle management, the Healthcare Billing and Management Association (HBMA) was invited recently to participate in discussions with the National Committee on Vital and Health Statistics (NCVHS) Subcommittee on Standards in Washington, D.C. to provide an update on the status of transitioning from ICD-9-CM to ICD-10-CM by the October 1, 2014, effective date. 

In testimony before the NCVHS Subcommittee on Standards, Holly Louie, CHBME, chair of HBMA's ICD-10/5010 committee, presented the association's views on "lessons learned" from the 5010 implementation and how those lessons can and should be applied to avoid problems with ICD-10 implementation. NCVHS is charged with advising the Secretary of Health and Human Services on all HIPAA related matters. 

Louie was part of a panel of experts invited. In her testimony, she said, "HBMA believes that we must learn from the mistakes that were made in transitioning from 4010 to 5010, and undertake the transition from ICD-9-CM to ICD-10-CM in a way that demonstrates we learned those lessons."

Louie shared HBMA's concern that in order for there to be a successful transition from ICD-9-CM to ICD-10-CM, "We must allow the 'lessons learned' from the 4010 to 5010 transition last year to materially inform the implementation of ICD-10-CM." Louie pointed out to the subcommittee that "The economic stability of America's health care reimbursement system will be at risk and could be severely compromised, affecting provider financial viability and patients' access to care."

The Centers for Medicare and Medicaid (CMS) has already delayed the effective date for ICD-10-CM implementation from October 1, 2013, to October 1, 2014. Speaking about this delay, Louie said, "It is imperative that the time gained by the delay be used wisely in order to ensure that the transition is successful. If we fail to learn the lessons we will merely be delaying the likelihood for payment disruptions and patient access to care problems from 2013 to 2014."

HBMA strongly recommends the following:

  1. While CMS has adopted a definition of "ready" and developed the tools and checklists to assist every provider, organization, payor, and vendor to validate they are ready on October 1, 2014, a subsequent announcement by CMS that they will not perform any external testing is extremely problematic for the industry. End-to-end testing by all payors, to meet the definition of "ready," must occur to ensure a smooth ICD-10-CM implementation. Failure to engage in meaningful end-to-end testing is a recipe for disaster.
  2. CMS must establish period benchmarks that cannot be ignored to assess the "readiness" status for all facts of the health care industry.
  3. There must be clear pronouncement that there is no vendor, EHR, coding assist tool, map, crosswalk, or other product that will solve the problem of excellent medical record documentation and accurate coding. Physicians and staff must be fully prepared with adequate training to operate compliantly and not rely on false proclamations of marketed solutions.
  4. Payor policies will be critical to the appropriate adjudication of claims. Currently, there is a wide variance among payors in stated policies. It is imperative that policies are published by October 1, 2013, in order to allow adequate time for education and training, data analysis, and other preparations for ICD-10-CM. 
  5. Any payor that is currently only accepting claims by 4010 format must be fully 5010 compliant by January 1, 2014, in order to be ICD-10-CM ready. 

Source: Healthcare Billing and Management Association