Guest post by Michele Hibbert-Iacobacci, CMCO, CCS-P, vice president, information management and client services, Mitchell International.
The International Classification of Diseases – 10th Revision, Clinical Modification and Procedural Coding System’s (ICD-10-CM/PCS) implementation in the United States is being delayed yet again. According to the latest polls and surveys, there are many organizations (most who need to use it) that were ready to roll with the new classification on October 1st 2014. The change came about because the Senate approved a bill (H.R. 4302) on March 31, 2014, that delays the implementation of ICD-10-CM/PCS by at least one year and then a subsequent official announcement by CMS announced a forthcoming interim final rule that would set the new compliance date for October 1, 2015.
How will this new implementation date affect Property and Casualty payers and providers? For an industry that was not required to change, P&C was ready to go – mainly because of the dependency on payments and bill processing. The question was, “Will we see ICD-9 and/or ICD-10?”
Fortunately, from a processing perspective the P&C industry was prepared for most anything. Payers were creating processing systems and/or contracting with vendors who considered all possibilities including bills submitted with both codes and the submission of ICD-9 codes well after effective dates. These payers also considered the compliance environment as most are guided at the state level.
As difficult as it may be to be ready for the effective date of ICD-10 just to have it changed, most aspects are positive for property and casualty. Additional time for testing, communication to providers and overall education (external/internal) enhances the readiness for the new date. The negative is the cost – staff has been added and enhanced with testers, educators and coders for the initial date. Maintaining staffing levels for a longer period of time was not accounted for in most budgets. The cost will be higher to implement now and many companies did not plan on the additional timeline.
So how will this shake out moving forward? Providers will likely react by submitting ICD-10 codes to P&C payers before the implementation date of October 1, 2015. Payers will need to make decisions on how they will handle these claims since P&C is not guided by the same rules under HIPAA as the health side. Some payers may decide to turn these claims back to providers and others will translate to ICD-9 for payment. Compliance standards, whereby a state has implemented mandates on the use of code sets that need to be addressed and/or revisited, may also impact the way payers process ICD-10 codes prior to October 1, 2015.