In April, President Barack Obama signed into law the Protecting Access to Medicare Act of 2014, which provided another temporary sustainable growth patch and effectively derailed ICD-10 implementation for at least a year. Reactions ranged from relief to dismay, but regardless ICD-10 will not go into effect this year and healthcare stakeholders are left to reevaluate their implementation plans. CMS issued a statement on the expectation that HHS would soon release a final interim rule requiring ICD-10 implementation to take place Oct. 1, 2015. Tim Meakem, MD, medical director of ProVation Medical, describes documentation as one of the most important issues in ICD-10 preparation and walks through a step-by-step timeline for obtaining the documentation support needed to make the ICD-10 switch in an ambulatory surgery center.
1. Now. Review the ASC's preparation and assess what remains to be done. "It is likely that you will determine a need for a structured reporting system, but you may also need evidence to convince some of your physicians and nurses," says Dr. Meakem.
2. By November 2014. Examine possible solutions. If an ASC decides to acquire a structured reporting tool, look for:
• Deep medical content
• Ability to customize
• Workflow structured around the delivery of care
• Quality reporting capabilities
• Ability to capture data for care improvement, marketing or payer negotiations
Avoid elements such as:
• Templates. These require the physician to know what details of documentation are required for coding and reporting.
• Coding pick lists. These should be electronically linked to the documentation recorded.
3. By January 2015. Commit to a solution, whether it is the purchase of a reporting tool or not. "Different ASCs have different timelines for purchase completion, and I allowed for two months to complete the approval process," says Dr. Meakem. "If your system takes longer, then extend accordingly."
4. By July 2015. Put the solution into practice. "You will want to ensure that all is going as projected and also allow time to make any adjustments needed before the switch," says Dr. Meakem. Train the center's staff and physicians to use the reporting tool and on the implementation plan's expectations. Conduct regular coding and documentation audits to ensure the demands of ICD-10 will be met. Test with payers as frequently as possible to identify any issues that need to be addressed.
6. October 2015. Complete the transition to ICD-10. Another delay is possible, but depending on another delay will leave the center unprepared if the transition date is final. "ICD-10 is needed because we are out of codes for ICD-9," says Dr. Meakem. "Only the timing is uncertain, but ultimately it will happen."
More Articles on Coding and Billing:
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5 Top ASC Documentation Issues Impacting Reimbursement & Their Solutions
CMS Cancels July ICD-10 Testing