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Beginning the Transition to ICD-10-CM/PCS Sue Bowman, RHIA, CCS Director, Coding Policy and Compliance American Health Information Management Association © 2009 Migrating to ICD-10 -- History • ICDA-8 ICD-9-CM – 1979 • Prospective Payment – 1982-1983 • ICD-9 ICD-10 – WHO 1990s • US Change – or lack thereof • US Readiness • HIPAA and HIPAA transactions • Hearings – studies -- hearings • 2008 Proposed Rules • Today 2 © 2009 Migrating to ICD-10 -- Code Sets • ICD-9-CM diagnosis coding system –US clinical modification of WHO’s ICD-9 –ICD-9-CM diagnosis codes are used by all providers –Maintained by National Center for Health Statistics • ICD-9-CM procedure coding system –developed by HCFA (now CMS) –ICD-9-CM procedure codes are used by hospitals for inpatient reporting –Maintained by CMS 3 © 2009 Migrating to ICD-10 -- Code Sets • ICD-10 – Diagnosis coding system developed by WHO as a replacement for ICD-9 – Implemented for mortality coding in the US in 1999 • ICD-10-CM – US clinical modification of the WHO’s ICD-10 – Diagnosis coding system (no procedure codes) • ICD-10-PCS – Developed by CMS to replace the ICD-9-CM procedure coding system 4 © 2009 ICD-10-CM/PCS Final Regulation • Compliance date of October 1, 2013 applies to: – All HIPAA covered entities – All claims received for encounters and discharges occurring on or after this date • It is in the best interest of non-covered entities to transition to ICD-10-CM/PCS on 10/1/2013 as well – ICD-9-CM will no longer be maintained – Increased detail in ICD-10-CM/PCS is of significant value to non-covered entities 5 © 2009 ICD-10-CM/PCS Final Regulation • ICD-10-CM will be used in all healthcare settings • ICD-10-PCS will be used for facility reporting of hospital inpatient services • CPT® and HCPCS Level II will continue to be used for: – Reporting physician and other professional services – Procedures performed in physician practices, hospital outpatient departments, and other outpatient settings 6 © 2009 Changes: ICD-10-CM Structure ICD-9-CM ICD-10-CM • 3-5 characters • First character is numeric or alpha (E or V) • Characters 2-5 are numeric • Always at least 3 characters • Use of decimal after 3 characters • Alpha characters are not case-sensitive • • • • 7 • • • • 3-7 characters Character 1 is alpha Character 2 is numeric Characters 3-7 are alpha or numeric All letters except U Always at least 3 characters Use of decimal after 3 characters Alpha characters are not case-sensitive © 2009 Changes – Classifications ICD-9-CM Structured Format Numeric or Alpha (E or V) V X E 4 5 Numeric X 1 Category X 4 . X 0 X 0 Etiology, anatomic site, manifestation 3 – 5 Characters 8 © 2009 Changes – Classifications ICD-10-CM Structured Format Alpha (Except U) 3 - 7 Numeric or Alpha Numeric M X X A S 3 X 2 Category . Additional Characters X 0 X 1 X 0 A X Etiology, anatomic site, severity Added code extensions (7th character) for obstetrics, injuries, and external causes of injury 3 – 7 Characters 9 © 2009 How Does ICD-10-CM Differ From ICD-9-CM? • Alphanumeric (alpha characters are not casesensitive) • Addition of a 6th character • Added 7th character for obstetrics, injuries, and external causes • Addition of dummy place holder (“x”) • Certain diseases have been reclassified to reflect current medical knowledge • Specificity and detail have been significantly expanded – non-specific codes are still available when detailed documentation is unavailable 10 © 2009 ICD-9-CM v ICD-10-CM Sample Codes ICD-9-CM ICD-10-CM • 707.05 Pressure ulcer buttock • 707.22 Pressure ulcer stage II • 707.24 Pressure ulcer stage IV • L89.111 Decubitus ulcer of right buttock limited to breakdown of the skin • L89.124 Decubitus ulcer of left buttock with necrosis of bone OR • L89.121 Decubitus ulcer of left buttock limited to breakdown of the skin • L89.114 Decubitus ulcer of right buttock with necrosis of bone 11 © 2009 ICD-9-CM vs. ICD-10-CM Sample Codes ICD-9-CM • 996.09 Other mechanical complication of cardiac device, implant, and graft • 909.3 Late effect of complications of surgical and medical care ICD-10-CM • T82.223A Leakage of biological heart valve graft, initial encounter OR • T82.223D Leakage of biological heart valve graft, subsequent encounter • T82.223S Leakage of biological heart valve graft, sequela 12 © 2009 ICD-9-CM vs. ICD-10-CM Sample Codes ICD-9-CM ICD-10-CM • 414.01 Coronary atherosclerosis of native coronary artery AND • 411.1 Intermediate coronary syndrome • I25.110 Atherosclerotic heart disease of native coronary artery with unstable angina pectoris 13 © 2009 ICD-9-CM vs. ICD-10-CM Comparison ICD-9-CM Mechanical Complication of Other Vascular Device, Implant and Graft: one code (996.1) ICD-10-CM Mechanical Complication of Other Vascular Grafts : 156 codes Type Device Episode of Care Breakdown Graft, Aorta Initial encounter Leakage Graft, Carotid artery Subsequent encounter Displacement Graft, Femoral artery Sequela (late effect of injury) Other (e.g., Obstruction) Dialysis catheter Arteriovenous fistula Arteriovenous shunt Counterpulsation balloon Infusion catheter Umbrella device 14 © 2009 Changes Go Beyond the Codes …. Myocardial Infarction Abortion vs. Fetal Death Obstetrics 15 • ICD-9-CM: 8 weeks, episode of care • ICD-10-CM: 4 weeks, no episode of care • ICD-9-CM: 22 weeks • ICD-10-CM: 20 weeks • ICD-9-CM: Episode of care • ICD-10-CM: Trimester © 2009 Changes: ICD-10-PCS – Structure 16 ICD-9-CM ICD-10-PCS • ICD-9-CM has 3-4 characters • All characters are numeric • All codes have at least 3 characters • ICD-10-PCS has 7 characters • Each can be either alpha or numeric • Numbers 0-9; letters AH, J-N, P-Z • Alpha characters are not case-sensitive • Each code must have 7 characters © 2009 Change: ICD-10-PCS – Structured Format ICD-9-CM X 1 X 2 . X 4 X 3 ICD-10-PCS X 3 D 1 0 X E 0 H X B 0 X F 0 X 5 7 X 8 Z 0 X 3 Z 4 17 © 2009 Change: ICD-10-PCS – Structured Format Characters (Medical/Surgical) 1 2 4 Root Operation Section Body System 18 3 5 6 Approach Body Part 7 Qualifier Device © 2009 ICD-9-CM Suture of Artery: One code 39.31 ICD-10-PCS Repair of Artery: 195 codes Approach Body Part 0-Open Abdominal Aorta 3-Percutaneous Common Carotid Artery 4-Percutaneous Endoscopic Radial Artery … … … … … 19 65 Different Arteries © 2009 ICD-9-CM Suture of Artery: one code (39.31), MSDRGs 252-254 (MDC 5) ICD-10-PCS Repair of Artery: 195 codes, MS-DRGs 252-254, 237-238 (MDC 5) Approach Body Part 0-Open Abdominal Aorta 3-Percutaneous Common Carotid Artery 4-Percutaneous Endoscopic Radial Artery … … … … … 65 Different Arteries 20 © 2009 Implications of Transition • Scope and complexity are significant • More widespread use of coded data than when the US last transitioned (to ICD-9-CM) • Data trending challenges are likely • Potential problems during initial transition period (e.g., increased payment delays, high coding error rates) can be mitigated with proper advance preparation 21 © 2009 Implications of Transition • Transition will permit: – More accurate payment, improved patient safety, and better patient outcomes due to higher-quality data – Improved clinical documentation and coding accuracy – Improved administrative efficiencies and lowered administrative costs – Better detail to utilize standard electronic health records and population health reporting including facility comparisons – Decrease in compliance risks – Development of more sophisticated computerassisted coding technologies that will revolutionize the coding process 22 © 2009 Implications of Transition – Who? • Providers – – – – Hospitals Physicians Outpatient facilities Post-acute providers (home health agencies, skilled nursing facilities, etc.) • Health plans or payers – Third party administrators – Employers • Others – – – – – Laboratories Free standing ancillaries Researchers Public health agencies et al. Data collection agencies/organizations (registries) – Vendors – Clearinghouses – Business associates and partners • Patients 23 © 2009 Implications: Mapping Between Old and New Systems • General equivalence maps (GEMs) between ICD9-CM and ICD-10-CM/PCS have been developed • Maps should NOT be used for coding medical records ICD-9-CM ICD-9-CM GEMs 24 GEMs Maps GEMs Maps = ICD-10-PCS via CMS web site ICD-10-CM via CMS /NCHS web sites Crosswalks © 2009 Implications: Mapping Between Old and New Systems • GEMs were developed as a general purpose translation tool for use by all providers, payers, and data users – Free of charge and in public domain • GEMs are designed to aid in converting applications and systems from ICD-9-CM to ICD-10-CM/PCS • Every conversion project won’t necessarily need to use the GEMs • GEMs were designed as a starting point – they are the foundation upon which applied mappings can be built 25 © 2009 Implications: Mapping Between Old and New Systems • Reimbursement map added to CMS web site in 2009 –Intended for use by payers –Temporary mechanism –Allows claims processing by legacy systems 26 © 2009 Implementation Phases • Phase 1 – Impact Assessment – Assessing impact of the change to ICD-10CM/PCS code sets and identifying key tasks and objectives – Conducting gap analysis • Phase 2 – Preparing for Implementation – Implementation of required information systems changes – Follow up assessment of documentation practices – Increasing education of the organization’s coding professionals – Items carried over from Phase 1 27 © 2009 Implementation Phases • Phase 3 – Go-Live Preparation – – – – – Finalization of system changes Testing of claims transactions with payers Intensive education of coding professionals Monitoring of coding and reimbursement accuracy Items carried over from Phase 2 • Phase 4 – Post-implementation – Assessment of impact on operations, data quality, reimbursement, coding productivity – Additional education as needed 28 © 2009 Impact of Coding System Change: 7 Steps 1. Develop Strategy 2. Communicate 3. Assess Readiness 4. Inventory Process/ System Impact 5. Plan Training 6. Documentation Improvement 7. Develop Budget 29 © 2009 Impact Assessment: Develop Strategy • Develop organizational implementation strategy –Establish a multi-disciplinary implementation planning team and designate leader –Develop internal timeline, including resources required –Develop organization-wide implementation plan 30 © 2009 Impact Assessment: Communication • Communication management strategies –Minimize “fear of change” and fear from rumors –Establish on-going communications with all affected groups –Ensure external communication liaisons are appointed and recognized 31 © 2009 Impact Assessment: Communication • Build Awareness – Orient key personnel – Basic familiarity with structure, organization, and unique features of new systems (on-going) – Provide understanding of how the new classifications fits into internal and external transitions including electronic health records, health information exchange, and health reform – Provide an understanding of how your strategy fits with the environment at your institution 32 © 2009 Impact Assessment: Assess Readiness • Assess organizational readiness for HIPAA, ICD, and other system, processes and data changes – effects on: – information systems using 4010/4010a and ICD-9CM (Where is ICD-9-CM?) – documentation process and work flow – data availability and use (Now v future?) – staff: medical, clinical, and administrative – current plans and acquisitions – organizational and vendor capacities 33 © 2009 Impact Assessment: Inventory • Assess what processes or systems will be impacted: – HIM/Coding Systems – DRG grouper – Encoding software – Abstracting systems – Compliance software – Claims or billing systems – Other systems – Future systems (on order/considered) 34 © 2009 Implementation – Impact Assessment: Inventory Billing/ Financial • • • • • • • • Reporting DRG grouper Conversion of other payment methodologies National and local coverage determinations System logic and edits Billing systems Financial systems Claim submission systems Compliance checking systems • Provider profiling • Quality measurement • Utilization management • Disease management registries • Other registries • State reporting systems • Fraud management • Aggregate data reporting • Clinical systems • Patient assessment data sets (e.g., MDS, PAI, OASIS) • Managed care reporting system (HEDIS) HIM • • • • • DRG grouper Encoding software Abstract systems Compliance software Medical record abstracting Clinical Systems Registration • • • • Registration and scheduling systems Advance Beneficiary software Performance measurement systems Medical necessity edits Support Systems • • • • • • • • • • • • Clinical protocols Test ordering systems Clinical reminder systems Medical necessity software Disease management systems Decision support systems Clinical systems Pharmacy systems Case mix systems Utilization management Quality management Case Management © 2009 Impact Assessment: Inventory • Orient IS/IT personnel on specifications of code sets • Perform comprehensive systems audit – Inventory databases and systems – Screens and input – Map electronic data flow to inventory all reports containing ICD-9-CM – Detailed analysis of system changes needed • Determine testing that will be needed – Vendors – Trading partners 36 © 2009 Impact Assessment: Inventory Determine required software changes • Field size expansion • Alphanumeric composition • Use of decimals • Redefinition of code values • Longer code descriptions 37 • Edit and logic changes • Modification of table structures • Expansion of flat files containing diagnosis codes • Systems interfaces © 2009 Impact Assessment: Inventory • Determine length of time for legacy and new coding systems • Determine which reports require modification • Forms redesign • Budgetary implications – hardware/software • Vendor readiness and timelines • Build flexibility for future upgrades 38 © 2009 Impact Assessment: Plan Training • Assess educational needs and develop budget plan – Who will need education? – What type and level of education will they need? – How will the education be delivered? Timing of education for what groups? – Who will need early education for implementation and training tasks? • Multiple categories of users of coded data will require varying levels of training • All coders will not require the same level of training 39 © 2009 Impact Assessment: Plan Training – Who? • Coders • Clinical department managers • Other HIM • Ancillary departments • Clinicians • Data analysts • Senior management • Researchers • Information systems • Epidemiologists • Quality management • Software vendors • Utilization management • Performance improvement • Accounting • Compliance • Business Office • Data quality management • Auditors and consultants • Data security • Patient access and registration • Data analysts 40 © 2009 Impact Assessment: Documentation Improvement • Conduct gap analysis of coding and documentation practices – Assess adequacy of staff knowledge • Measure coding professionals’ baseline knowledge of anatomy, physiology, pharmacology, and medical terminology • Identify areas of weakness and provide targeted education if necessary – Assess adequacy of medical record documentation to support level of detail in new coding systems – implement documentation improvement strategies as needed 41 © 2009 Impact Assessment: Develop Budget • Develop budget – Departmental budget responsible for costs • Systems, hardware, software, education – Increased staffing? • Impact on productivity and accuracy – Short-term (during learning curve) and long-term – More sophisticated computer-assisted coding technologies and advances in mapping from clinical terminologies will improve productivity and accuracy • Consulting services – Backlogs – Monitoring coding accuracy – Other support – Allocate costs over multiple years 42 © 2009 “Lessons Learned” from Other Countries • Starting early is key to success • Importance of planning and preparation • Six-month learning curve • Vendor readiness is extremely important • Communication is critical • Targeted significant ICD-9/ICD-10 comparability issues 43 © 2009 Expectations: Bottom Line on Preparation (Goals) • Maintain coding productivity • Maintain coding accuracy • Reduce claims rejections and denials • Maintain account receivables • Proper claims payment • Reduce risk of compliance issues • Decisions based on improved data 44 © 2009 Expectations: ICD-10-CM and ICD-10PCS in 2013 • Compliance deadlines were set per public comments • Federal government expects compliance deadlines to be met – no extensions • Initial payments will not reflect new codes • Codes will likely be “frozen” for some period of time • Success will depend on starting early! 45 © 2009 CMS Resources • ICD-10 General Information http://www.cms.hhs.gov/ICD10 • ICD-10 Educational Resources (fact sheets) http://www.cms.hhs.gov/ICD10/05_Educational_Resources.as p • ICD-10-PCS files, information, and General Equivalence Mappings (GEM) between ICD-10-PCS and ICD-9-CM http://www.cms.hhs.gov/ICD10/01m_2009_ICD10PCS.asp • 2009 and 2008 ICD-10 CMS Sponsored Calls http://www.cms.hhs.gov/ICD10/06a_2009_CMS_Sponsored_C alls.asp http://www.cms.hhs.gov/ICD10/07_Sponsored_Calls.asp 46 © 2009 CDC Resources • General ICD-10 information http://www.cdc.gov/nchs/about/major/dvs/icd10 des.htm • ICD-10-CM files, information, and General Equivalence Mappings (GEM) between ICD-10-CM and ICD9-CM http://www.cdc.gov/nchs/about/otheract/icd9/icd 10cm.htm 47 © 2009 AHIMA Resources http://www.ahima.org/icd10 • • • • • • • • Practical guidance Articles Online courses Proficiency assessments Books Webinars/Conferences E-newsletter Academy for ICD-10-CM/PCS Trainers • Frequently Asked Questions ―Submit questions for list [email protected] 48 • New resources – Practice briefs – Implementing ICD-10CM/PCS for Hospitals (book) – Pocket Guide of ICD-10CM and ICD-10-PCS (available by the end of 2009) © 2009 Questions Sue Bowman, RHIA, CCS Director, Coding Policy and Compliance American Health Information Management Association 233 North Michigan Avenue Chicago, IL 60601 Telephone: (312) 233-1115 E-Mail: [email protected] © 2009