August 11, 2015
5 min read

Transition to ICD-10 codes requires keen oversight, rigorous training

For 1 year, CMS will not deny claims based solely on specificity of the code when it is within the appropriate family of codes.

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Practices have until Oct. 1 to successfully upload, test and implement ICD-10 codes, which will replace the ICD-9 code set.

In 2012, CMS delayed the deadline for implementing ICD-10 from Oct. 1, 2013, to Oct. 1, 2014. In March 2014, the U.S. Senate delayed the implementation deadline from Oct. 1, 2014, to Oct. 1, 2015.

ICD diagnosis and procedure codes, published by the WHO, are used to complete forms submitted to private insurance companies, Medicare and Medicaid for reimbursement.

According to Donna McCune, CCS-P, COE, CPMA, vice president of Corcoran Consulting Group, practices need to ensure that documentation is updated in paper or electronic medical records.

Donna McCune

“ICD-10 coding relies on significant detail in the impression area of the chart in order to select a code,” McCune told Ocular Surgery News. “What we would advocate as part of the preparation process is to start focusing on your current documentation and improving that, and then to move forward with beginning to try to code with ICD-10 codes from your documentation.”

Training for physicians and staff is critical, according to Michael X. Repka, MD, MBA, American Academy of Ophthalmology medical director for governmental affairs.

Michael X. Repka

“Billing staff should be doing some kind of specific training to familiarize themselves with the nuances,” Repka said.

Upgrade and test systems

The transition to ICD-10 should be virtually seamless for practices that have EHR systems, Repka said.

“There are some things to do for people that are not on an electronic platform. For docs who are on EHRs, there’s not a lot to do. People who don’t have a fully integrated coding system with their EHR will have a little bit of work to do,” he said.

A checklist for the ICD-10 transition posted on the AAO website recommends that practices have EHR vendors upload ICD-10 codes and upgrade their EHR systems to versions that support ICD-10.

“They need to confirm with their EHR companies that the codes are going to be loaded,” McCune said. “Practices need to have that level of comfort that the codes truly are in their systems and, when they need them, they’re going to be able to access them.”

The checklist also advises practices to start identifying the appropriate ICD-10 codes for each procedure but to submit ICD-9 codes for payment before Oct. 1; then, beginning Oct. 1, ICD-10 codes should be reported.

Physicians and administrators should also confirm that their EHR vendors have upgraded and tested claim submission systems.

“The idea that they can confirm that claims are able to go from their computer to the third-party payer computer with ICD-10 codes on them and be received is a very important aspect of preparation,” McCune said. “Everyone’s fear is that, come Oct. 1, their claims are going to crash and burn and fall into a big black hole and nobody will ever see them again.”

AMA, CMS ease transition

The American Medical Association (AMA) and CMS on July 6 together announced their efforts to facilitate the transition to ICD-10, with CMS issuing new guidance aimed at addressing frequently asked questions anticipated from health care providers.

Among provisions in the guidance is a 1-year grace period, starting Oct. 1, in which “Medicare claims will not be denied solely on the specificity of the ICD-10 codes provided, as long as the physician submitted an ICD-10 code from an appropriate family of codes,” Repka said. “In addition, Medicare claims will not be audited based on the specificity of the diagnosis codes, as long as they are from the appropriate family of codes. This policy will be followed by Medicare administrative contractors and recovery audit contractors.”

Recognizing that mid-year coding changes could affect CMS quality programs, the CMS guidance says that, for the 2015 reporting year, physicians using the appropriate family of diagnosis codes will not be penalized if CMS experiences difficulties accurately calculating quality scores, for example, for the Physician Quality Reporting System, Value Based Modifier and Meaningful Use. CMS will monitor implementation and make adjustments if needed.


According to Repka, the CMS guidance also allows for authorization of advanced payments if Medicare contractors are unable to process claims within established time limits due to problems with ICD-10 implementation.

In another effort to facilitate transition to ICD-10 and in response to a request by the AMA, CMS will name an ICD-10 Ombudsman “to triage and answer questions about the submission of claims,” according to the joint announcement from the two organizations.

Activities and resources

CMS held testing sessions for ICD-10 in March, June and July.

“We’re very positive as far as showingthe ability to receive the claims,” McCune said. “That’s what the testing process is all about, so that they can make sure that they read the claims and then are able to process them. I think CMS, [Blue Cross], United Healthcare and the other big payers have been preparing for 3 years. They really have done, in my opinion, a very good job with preparation.”

The AAO posted information on converting superbills for ICD-10, Repka said.

“There also has been some information for people still using paper superbills on how to convert from the ICD-9 superbills to the ICD-10 superbill,” he said.

In a document posted on the AAO website, the authors advise practices to be strategic, account for diagnoses, avoid general equivalence mappings and leverage their EHR systems.

Interactive cases studies are available on the Corcoran Consulting Group website, McCune said. CMS also features instructional videos on its YouTube channel. – by Matt Hasson

Disclosures: McCune is vice president of Corcoran Consulting Group. Repka is AAO medical director for governmental affairs.