Commentary: ICD-10 arrives early in new claims form

By Michael F. Arrigo
08:29 AM
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The U.S. Health and Human Services (HHS) Centers for Medicare and Medicaid (CMS) announced on Thursday that Medicare will begin accepting a revised CMS-1500 form (version 02/12)  on January 6, 2014.

Embedded in this is a requirement for some healthcare IT vendors to start supporting a component of the International Classification of Diseases version 10 (ICD-10) earlier than the anticipated October 1, 2014 date.

Starting April 1, 2014, Medicare will accept only the revised version of the form. The revised form will give  HIPAA Covered Entities who are health care providers the ability to indicate whether they are using ICD-9 or ICD-10 diagnosis codes, which is important as the October 1, 2014, transition approaches. Effectively this means that any healthcare IT system that adjudicates, submits, or reports on claims data that was scheduled to be compliant as of October 1, 2014 with ICD-10 must actually comply with a component of the ICD-10 requirements related to claims data as early as of April 1, 2014.

ICD-9 codes must be used for services provided before October 1, 2014, while ICD-10 codes should be used for services provided on or after October 1, 2014. The revised form also allows for additional diagnosis codes, expanding from 4 possible codes to 12. ICD-10 CM must be used for all diagnosis for both inpatient and outpatient claims. ICD-10 PCS must be used for all inpatient procedures.

Only providers who qualify for exemptions from electronic submission may submit the CMS-1500 Claim Form to Medicare. For those providers who use service vendors, CMS encourages them to check with their service vendors to determine when they will switch to the new form.

[See also: Will ICD-10 trigger a last-minute IT vendor conundrum?]

ICD-10 promises to introduce better information to improve the quality of healthcare by providing more granular data on the condition of the patient, how the patient acquired a condition, how the patient was treated for the condition and why. This in turn it is hoped, will improve population health management and other components of healthcare. 

At the same time ICD-10 is viewed as disruptive because it requires a re-write of healthcare IT systems, processes, and substantial re-training of medical coders, billing personnel, physicians, and other clinical staff. 

From a financial perspective ICD-10 introduces a new payment paradigm including opportunities for improved reimbursement and potential risks of decreased reimbursement for HIPAA Covered Entities who do not carefully examine the nuances of the ICD-9 to ICD-10 transition.

HIPAA Covered Entities and healthcare IT vendors who are building test plans must take this into consideration as they plan for the ICD-10 transition.

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