ICD-10 Compliance

William R. Pupkis, CMPE, Healthcare Consultant
ICD-10-ComplianceThe tenth revision of the International Classification of Disease (ICD-10) is a medical classification list by the World Health Organization (WHO). It codes for diseases, signs and symptoms, abnormal findings, complaints, social circumstances, and external causes of injury or disease. Due to a bill (Protecting Access to Medicare Act) approved by the Senate and signed by the President on April 1, 2014, the expected compliance date for ICD-10 has been delayed from October 2014 to October 2015. As this article goes to press, the Centers for Medicaid and Medicare Services (CMS) are still “examining the implications of the ICD-10 provision and will provide guidance to providers and stockholders soon.”

The new ICD-10 code set for the United States includes about 69,000 different codes and permits the tracking of many new diagnoses. There is a code if you are struck by a turkey and another if you are bitten by a turkey, and then one if struck by a parrot, and yes, another if bitten by a parrot, and others if injured by a squirrel or hit by a motor vehicle while riding a zebra.

From 2001 to 2006, Canada implemented ICD-10 in a staggered fashion across nine of its ten provinces. During that time, coder productivity experienced a 23% to 50% reduction. And, due to the complexity of the new system, has not yet fully recovered1.

"contact your major payers"

In addition to productivity issues, not being prepared to make the transition can affect your practice’s cash flow. While this may be hard to believe since these are diagnosis codes, not procedure codes, incorrect codes on claim forms could result in insurance companies rejecting your claims. In other words, reimbursement will be delayed, thereby affected cash flow. Also, insurance companies may have internal problems that can delay your reimbursements. They will need to have all of their coverage, payment pre-certification, and quality programs converted months prior to the “go live” date. You should be in contact with at least your major payers to assess their readiness to process your claims coded in ICD-10. In response to these and other issues, it would be wise to contact your bank about establishing, or expanding, a line of credit to offset the potential lag.

Consider this. If the physicians in your group are still dictating their notes, i.e., not using an EMR, they will need to be even more specific than they were using ICD-9 because your transcriptionists may not come up with the same code as the one the physician intended. You should also develop a plan for coding, billing, and claim backlogs, as well as for denials management pre and post ICD-10 conversion. Your practice will likely experience a higher rate of denials while physicians and staff adjust to the new documentation and coding requirements.

The CMS website provides material to help you make the transition. You can even sign up for email alerts to be notified of the latest updates. CMS has also created “Road to 10”,  an online resource with general ICD-10 information and references, as well as tools to help you build an action plan based on your practice’s specialty.

Additional Tips for Transitioning to ICD-10

  • Develop a check list of items to be done; assign a person to each of the items as well as a time line for completion
  • Determine how you will implement the changes
    • Send physicians to coding classes?
    • Hire an in-house coder?
    • Use electronic apps (such as for an iPad), integrated EMR programs, stand-alone programs with EMR/PM interfaces?
    • Employ “scribes” to train physicians?
  • Create a transition timeline and budget your resources, keeping in mind that the ICD-10 transition will also impact initiatives such as Meaningful Use or reporting under PQRS
  • Test your system prior to the launch date

The bottom line is that there are many issues to deal with prior to the deadline. While the unexpected delay can be frustrating, it does provide an opportunity to spread your expenses over a longer period and more closely evaluate and test your plans to transition to ICD-10.


1. Natale C. ICD-10-CA: What really went wrong in Canada. Healthcare IT News. Sept. 13, 2011. http://www.healthcareitnews.com/blog/icd-10-ca-what-really-went-wrong-canada?single-page=true. Accessed April 17, 2014.

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