It seems the ICD-10 implementation is not quite over for healthcare providers, according to an announcement made by the Centers for Medicare & Medicaid Services (CMS). Given previous delays in the ICD-10 go-live date, what are intended to be regular, more wide-scale updates to the code set (accounting for new procedures, diseases, or technology) have been stalled since 2011. As such, a significant number of codes have been awaiting their addition to the official code set, and it was decided the partial freeze on regular additions or revisions will be lifted exactly one year after go-live on October 1st, 2016.
With this in mind, the following provides a high-level overview of the federal processes that have contributed to the recent addition of ICD-10 codes—codes that may be added or adjusted—and the potential impact of this change.
Understanding Federal Processes
The decision to update the ICD-10 code set comes as a result of a March 9th meeting of the ICD-10 Coordination and Maintenance Committee, which is chaired by the National Center for Health Statistics, the Centers for Disease Control and Prevention (CDC), and CMS—all of which share the responsibility of updating or approving code changes. Released April 18th, the 2017 Hospital Inpatient Prospective Payment System (IPPS) affirms this decision, stating, “It was announced at this meeting that any new ICD-10-CM/PCS codes for which there was consensus of public support and for which complete tabular and indexing changes would be made by May 2016, would be included in the October 1st, 2016 update to ICD-10-CM/ICD-10-PCS.”
Exploring the New and/or Modified ICD-10 Codes
As a result, more than 5,500 new codes will be functional for claims originating in fiscal year 2017. This includes 1,900 diagnosis codes and 3,651 inpatient procedure codes that are now in a series of online tables, according to the 2017 IPPS proposed rule. Revisions will also be made to 487 code titles. From that point on, regular additions or changes will be made as procedures are innovated, diseases evolve, and more.
As only a few examples of the many potential codes being added or updated, the CDC introduced code A92.5, which indicates the diagnosis of the Zika virus. There have also been codes planned for face transplant, hand transplant, and donor organ perfusion procedures. CMS has also noted that 97% of the new hospital inpatient procedure codes are actually updates to cardiovascular systems—of which, 3,084 or 84% are meant to account for “unique device values for multiple intraluminal devices and to apply the qualifier Bifurcation to multiple root operation tables for all artery body part values.” Furthermore, changes to MS-DRGs will also be included in the October 1st, 2016 update.
Preparing for October 1st, 2016
It is likely not lost on revenue cycle or coding leaders that such a large installment of new codes will be coming right on the heels of CMS’ grace period—the one intended to provide some leeway in the specificity of ICD-10 codes applied. Up until October 1st, 2016, as long as the code applied is within the same family of codes as the appropriate code, no penalty will be applied and reimbursement will still be given. After this time, however, organizational leaders are largely expecting that denials will finally see the increases projected prior to the initial conversion in code set. CMS had projected that initial denials would double or even triple, but according to Academy survey results, most organizations have not yet seen a sizeable increase in denials as a result of ICD-10. With thousands of additional codes coming into the fold just as its grace period ends, it could be that CMS’ estimation will come to fruition at the start of next year.
With that being said, despite the thousands of additional codes certainly having the potential to place a strain on organizations once implemented, industry experts seem to predict that the burden will be placed more on external vendors than providers—as they must work to incorporate the changes into existing software. As much still remains to be seen, providers may find it beneficial to continue strengthening documentation and coding processes as much as possible now as opposed to a later date.
While the comment period has already ended as of April 8th on the newest ICD-10 codes, the 2017 IPPS proposed rule encouraged those with questions or suggestions on coding issues to email firstname.lastname@example.org for diagnosis codes or ICDProcedureCodeRequest@cms.hhs.gov for procedure codes.
Recordings as well as minutes of the meetings held by the ICD-10 Coordination and Maintenance Committee—in addition to a list of changes and revisions—are posted on CMS’ website under the Medicare and “Transition from ICD-9-CM to ICD-10” tabs.