On October 1, 2016, the 1-year anniversary of ICD-10 implementation, the grace period extended by the Centers for Medicare and Medicaid Services (CMS) for ICD-10 flexibility on physician and practitioner claims is set to end.
ICD-10 was implemented on October 1, 2015. Prior to its implementation, on July 6, 2015, after months of significant pressure from the American Medical Association (AMA) and other physicians groups, CMS announced flexibility in its enforcement of physician and practitioner claims. As reported on the McDermottPlus website, CMS announced that for the first 12 months after ICD-10 implementation, physician or other practitioner claims billed under the Part B physician fee schedule will not be denied solely on the specificity of the ICD-10 diagnosis code as long as a code from the right family is used.
In a recently updated FAQ document posted on the CMS website, CMS confirmed that they will not extend this flexibility beyond October 1, 2016. CMS states in the guidance, "As of October 1, 2016, providers will be required to code to accurately reflect the clinical documentation in as much as specificity as possible, per the required coding guidance."
CMS noted in the FAQ, that while the coding flexibility offered in the first year of ICD-10 implementation may have been helpful to many providers, since not all insurers offered this flexibility, some providers are already using specific codes.
The transition to ICD-10, which created anxiety throughout the healthcare industry, was fraught with multiple delays and took years to come to fruition. Despite the many dire predictions of chaos that would result from ICD-10 implementation, by most accounts the first year has been generally smooth and CMS did not experience a significant uptick in denials. With the end of the flexibility period looming, there remains concern that some practices still are not ready and the end of the flexibility could cause an increase in denied claims and as a result disruptions in payments.
Whatever happens after October 1, 2016, ICD-10 compliance and claim denial rates will be closely monitored by CMS and numerous stakeholder groups. McDermottPlus will continue to monitor the situation.
ICD-10 Flexibility Ends On October 1, 2016
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