Warning: ICD-10 Deadlines Are Closer Than They Appear

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Amy Shellhart By Amy Shellhart 
Regulatory Product Manager, McKesson
Two women conducting an ICD-10 training for home health

Assuming that ICD-10 is not delayed at the last minute (again), we are just a few months from the changeover. Tricia Twombly points out that the deadline is closer than it appears—because of home health’s prospective payment system, many organizations will need to submit ICD-10 codes on claims on August 3.

Twombly provides ICD-10 training for home health organizations and is a senior director at DecisionHealth. She has sound advice for home health organizations, regardless of where they are in the ICD-10 preparation process.

  1. Take CMS estimates with a grain of salt. Twombly said CMS estimates each coder will need 16 hours of initial training and eight hours of gap knowledge deficit training for a total of 24 hours. But Canadian healthcare organizations encountered significantly higher training demand: 50 hours of initial training and 15 hours of gap knowledge deficit training. Canadian organizations also saw a 54% decrease in coder productivity during the first 12 months and a 20% permanent decrease. “If a coder is doing 25 assessments per day right now, that could drop to 11.5 in the first 12 months and only come back to 20 assessments per day,” says Twombly.
  2. Don’t assume you’re off the hook if you outsource coding/billing. You’ll still need at least one person in your organization with an intimate knowledge of ICD-10 so that you can double check the vendor’s work, Twombly notes. That person or team must also examine rejected claims to determine where home health documentation errors are occurring.
  3. Don’t forget to thoroughly train your intake team. Twombly said her experience shows that a well-trained intake team can mean the difference between a smooth transition and a bumpy one. Your intake staff’s understanding of the new coding system will allow them to gather as much clinical information as possible while they have the referral source on the phone. They also should be provided with questions to ask the referral source for all common diagnoses. For example, if a patient has a fracture, they should know to ask, “Could you provide the radiology report that includes the location and type of fracture?” Similarly, if a patient has congestive heart failure, they should ask whether the condition has a diastolic or systolic component.
  4. Secure a line of credit. Twombly says experts recommend home care organizations have enough cash or a line of credit to keep them operating for six months with no revenue. She acknowledged that this scenario is unlikely, but that doesn’t preclude the wisdom of finding a bank that understands the specialized financing requirements of healthcare practitioners.
  5. Be prepared to dual code on August 3. CMS has stated that if the request for anticipated payment (RAP) date is before October 1, 2015, but the M0090 date is after October 1, ICD‐10 codes should be used on the OASIS‐C1‐I10. ICD‐9 codes are to be reported on the RAP in order for it to be processed, and the HIPPS code will be generated with ICD‐10 payment.

Finally, Twombly stresses the importance of CMS’s statements about unspecified codes. “CMS is clearly considering a lower payment structure for unspecified codes,” she said. “Going forward, reducing or eliminating those codes should be a priority for all home health agencies.”

For a closer look at how one home care agency has been preparing for the transition to ICD-10, download our case study now.


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