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
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
Healthcare providers of all kinds have traditionally relied upon discounts as a legitimate means of attracting patients and commercial clients without running afoul of the federal anti-kickback statute (AKS).
On September 19 and 27, 2016, the US Department of Justice announced two False Claims Act settlements that required corporate executives to make substantial monetary payments to resolve their liability.
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