With the implementation of ICD-10 only 90 days away (October 1, 2015), the window for the transition from ICD-9 is rapidly closing for many physician practices. The California Medical Association (CMA), in collaboration with the American Medical Association and other medical associations, sent a letter to the Centers for Medicare and Medicaid Services (CMS) and Congressional leadership  urging them to help mitigate the impact of the transition by supporting a two-year grace period whereby physicians would use ICD-10 but not have claims delayed, denied or subject to audits because of simple ICD-10 errors or CMS system problems.

In addition, CMA, along with the large state medical associations (New York, Texas and Florida) also met with CMS last Friday to urge them to adopt the grace period and make advance payments available in the event that payments are seriously delayed. 

Implementation of ICD-10 coding will not only affect claims submission, it will impact most business processes within a physician’s practice, including verifying patient eligibility, obtaining pre-authorization for services, documenting a patient’s visit, research activities, public health reporting and quality reporting, the letter says. As learned from previous and significantly less complex claim processing changes (e.g., the National Provider Identifier and the upgrade to Version 5010 transactions), unanticipated problems can occur. These much less complex implementations resulted in many physicians going unpaid for weeks, and in some cases months, despite assertions by many parties (including Medicare) that they were ready and prepared for these changes.

Granting a grace period would not negatively affect determinations for coverage or fraud prevention efforts since physicians would continue to code diagnoses using ICD-10 and submit claims. Physicians would still be required to provide a valid ICD-10 diagnosis code relevant to the patient’s condition, but the transition period would allow for the acceptance of, for example, “Unspecified abdominal pain” where, with further understanding of the code set and guidelines, “Periumbilical pain” would be more precise. As long as physicians are trying to use the correct codes and are within the right family of codes, CMS would not hold up payments.   

The change to ICD-10 comes at a time when physician practices are struggling to remain viable among a myriad of new rules, regulations and programs, such as quality reporting,  adopting new health information technology, and moving to new delivery and payment models.

“We urge Congress to implement a transition period that ensures physicians will not be unfairly penalized for ICD-10 coding mistakes, errors or malfunctions of the system,” CMA said in the letter. “We believe implementing such a period will help mitigate any unforeseen problems and prevent potentially devastating outcomes for our nation’s physicians and patients."