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Is ICD-10 Dual Coding Proposal Even a Feasible Alternative?

By Jennifer Bresnick

- There has been no shortage of ICD-10 legislation hitting the House floor in the past couple of months as healthcare stakeholders seek new avenues for easing the predicted burden of the transition.  While even the most steadfast opponents have now accepted that ICD-10 implementation will almost inevitably take place on October 1, 2015, new suggestions for making the switch kinder and gentler for overburdened organizations continue to crop up

ICD-10 dual coding

The latest is a proposal by Rep. Marsha Blackburn (R-TN) that would require CMS to accept ICD-9 and ICD-10 for the first six months after the transition, theoretically allowing providers even more time to come to terms with their ICD-10 future.  The bill would establish a period “during which health care claims (and related standard transactions) otherwise payable (or processed) by public and private payers shall continue to be processed and paid, as applicable, if submitted with ICD–9 codes.”

On top of CMS’ recent assertion that claims will not be denied solely on the use of an ICD-10 code that may be less-than-ideally specific, the Code-FLEX Act (HR 3018) would give providers a great deal of leeway to make a soft landing into ICD-10. 

But long-term acceptance of both code sets at once isn’t necessarily the simple solution to a lack of ICD-10 preparedness.  Come April 1, 2016, providers will be faced with the same choice they would have on October 1, 2015: switch over to ICD-10 completely or stop getting paid.  Will an extra six months make a difference when providers have been staring down the same problem for several years without committing fully to completing their preparation?

The industry may already have its answer.  CMS has repeatedly stated that its claims processing systems, as well as the infrastructures of many private payers, are simply not capable of accepting ICD-9 and ICD-10 codes at the same time.  

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“CMS will not allow for dual processing of ICD-9 and ICD-10 codes after ICD-10 implementation on October 1, 2015,” the agency stated in industry guidance revised and released this spring. “Many providers and payers, including Medicare have already coded their systems to only allow ICD-10 codes beginning October 1, 2015.”

“The scope of systems changes and testing needed to allow for dual processing would require significant resources and could not be accomplished by the October 1, 2015, implementation date. Should CMS allow for dual processing, it would force all entities with which we share data, including our trading partners, to also allow for dual processing.”

While this may seem fine for ICD-10 opponents – after all, it might force lawmakers to push back the implementation date by another year or two in order to allow time for payers to upgrade all processing systems to accept dual coding – the ramifications for the industry at large would be significant. 

“Having a mix of ICD-9 and ICD-10 codes in the same year would have major ramifications for CMS quality, demonstration, and risk adjustment programs,” the issue brief points out, and dragging out the transitional period may produce millions more in unnecessary costs for providers who must maintain training programs and other implementation activities for an additional length of time.

“Any ICD-10 delay is disruptive and costly for healthcare delivery innovation, payment reform, public health, and healthcare spending,” says AHIMA in its ICD-10 FAQ sheet. “Considerable time and resources have been invested in financing, training, and implementing the necessary changes to workflow and clinical documentation. Each delay adds substantially to the cost of ICD-10 conversion – a one year delay is estimated to have cost the health care sector as much as $6.8 billion dollars.”

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The Coalition for ICD-10 has also come out strongly against the proposition that both code sets should be in use at the same time.  In addition to reiterating the technical problems involved in retooling claims processing to allow for dual coding, stakeholders from the nation’s major health plans have voiced concerns about the detrimental effect such a scheme would have on data integrity, clinical analytics, and quality reporting.

“Allowing both ICD-9 and ICD-10 for the same dates of service would create confusion for customer service staff supporting both members and providers, increase the complexity of linking claims between hospitals and providers, and make it much more difficult for fraud detection programs to identify aberrant billing patterns,” stated Justine Handelman, Vice President, Legislative and Regulatory Policy, Blue Cross Blue Shield Association in March. “It would also require costly reprogramming of all the EDI and processing systems and re-testing, which inevitably would lead to more delays as there is simply not enough time to change systems.”

“ICD-10 has already been delayed twice and should not be delayed again,” added Karen Ignagni, outgoing President and CEO of America’s Health Insurance Plans (AHIP). “The goal should be to make our system more efficient. Yet an interim ‘dual-coding’ process is inefficient, ineffective, and will only cause undue confusion and costly administrative challenges in processing payments.”

While concerns over the preparation status of small and financially vulnerable providers are certainly well-founded, the healthcare industry has had many years to come to terms with the fact that there will, at some point, be a final sunset for ICD-9. 

The majority of organizations have made a good-faith effort to get ready for the change, but those few providers who have still been banking on additional delays to stretch out the costs or educational requirements of switching to ICD-10 may finally be out of luck as October creeps closer with no signs of major movement towards another wholesale pushback.

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“You’re always going to find people falling behind,” Cassi Birnbaum, MS, RHIA, FAHIMA, CPHQ, 2015 President of AHIMA, told in October of 2014, when much of the industry expected the ICD-10 transition to take place. “Just like the person who always has an excuse for not getting their homework done – I mean yes, we can delay the inevitable for fifty years and they still wouldn’t be ready.”

CMS, AHIMA, and other advocacy organizations continue to release resources and provide training opportunities for providers who need extra help navigating the transition.  With less than 100 days until the October 1, 2015 deadline, providers concerned about their revenue cycle management may wish to visit the CMS ICD-10 training center located here.


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