CMS Provides Update for Transition to ICD-10 Codes

Since 1988, medical diagnoses and inpatient procedures have been coded for uniformity, using the International Classification of Disease, Ninth Edition or “ICD-9” codes. In October 2014, however, these diagnostic codes will be replaced by “ICD-10” code sets, which reflect updated medical procedures and allow for more specific data regarding patients’ medical conditions. All health care providers subject to the Health Insurance Portability Accountability Act (HIPAA) will need to follow the new system.

Now, the Centers for Medicare & Medicaid Services (CMS) have provided key information that companies who submit data to Medicare will need to adopt in order to transition to the new codes. Please note that this conversion to ICD-10 will impact the Mandatory Insurer Reporting rules under Section 111 of the Medicare Medicaid SCHIP Extension Act of 2007, which affect self-insured entities, liability insurers, no-fault insurance providers, and workers’ compensation carriers (collectively “Responsible Reporting Entities” or RREs). All RRE claim reports submitted to CMS with a Date of Incident on or after April 1, 2015 will be required to use ICD-10 codes.

Other key changes include:

• An ICD indicator field will be added to the report for the transition period to indicate whether the RRE is using ICD-9 or ICD-10 codes.
• During the transition period, RREs may only submit one version of diagnosis codes. If both ICD-9 and ICD-10 codes are on a record, that record will be rejected.
• The ICD fields will expand from 5 digits to 7 digits to accommodate the longer ICD-10 codes.
• As of October 1, 2013, RREs and Reporting Agents can begin testing ICD-10 codes in the test environment with the Coordination Of Benefits Contractor (COBC).
• As of October 1, 2014, the COBC will accept ICD-10 codes in production.
• Prior to April 1, 2015, the COBC will accept either ICD-9 or ICD-10 codes. But as of April 1, 2015, ICD-9 codes will be rejected.
• Between October 1, 2014 and March 31, 2015, claim response files will show a compliance flag for ICD-9 codes. This compliance flag serves as a reminder that ICD-10 codes will be required for DOI’s beginning April 1, 2015.
• As of October 1, 2013, ICD-9 diagnosis codes 959.8 and 959.9 codes will be excluded.
• A list of excluded ICD-9 and corresponding excluded ICD-10 codes can be found by clicking here.

Bottom Line:

RREs need to ensure that the deadlines for voluntary and mandatory use of ICD-10 codes are fully incorporated into their submission procedures. If the Garretson Resolution Group is your Reporting Agent, our systems will be programmed to fulfill these new requirements.

If you have questions, please contact Marlene Wilson (mwilson@garretsongroup.com) at 704-559-4300.