Clock Is Ticking on ICD-10 Grace Period

Emily Brill
Published: Monday, Aug 08, 2016
Debra Patt, MD

Debra Patt, MD

ICD-10 was last year, right? Isn’t it old hat now? Think again. Oncology practices are facing a new deadline. When October 1 arrives, they will have to start coding with greater specificity and also get used to many new codes that CMS is going to activate. The one-year grace period that followed last year’s inauguration of ICD-10 is about to end.

“The next big challenge will be when the grace period is over, when you can be audited and have claims denied based on not supplying a specific enough code,” said Risë Cleland, the founder of Oplinc, an oncologyfocused healthcare consulting company based in the Pacific Northwest.

“That will also translate to what’s in your medical record documentation, because you will also have to have the medical record documentation that backs up the particular code you’re using and the level of specificity.”

Even so, Cleland said she does not expect a huge increase in denials up front. Many electronic health record (EHR) systems generate a suggested code level for office visits automatically, based on information entered into the system, she said—so that if an office is audited or a claim denied, physicians have all the documentation in the EHR to justify the codes. “More accurate and specific diagnosis coding can help to demonstrate medical necessity for the appropriate office visit level,” Cleland said.

Roughly 1,900 new diagnostic codes and 3,650 new hospital inpatient codes will become valid come October. That’s on top of the tens of thousands of new codes introduced last year. To prepare for the higher level of accountability and the increased potential for CMS audits resulting from improper code use, practices have been analyzing their internal systems for signs of inappropriate code use that could lead to trouble when the grace period ends.

ICD-10: The First Deadline

The changeover last year was the biggest upgrade to medical coding in years. Leading up to the big day, doctors and administrators weren’t sure how it would unfold. They had sat through hours of training sessions about how to adapt to ICD-10, which would increase the number of diagnostic codes from 13,000 to 68,000. They had witnessed changes to their practices’ business offices and updates to EHR software. They had been told of the risks of implementing the ICD-10 update improperly and, after the change, adapting to the new classification system ineffectively. The atmosphere was thick with anticipation, questions, fear.

“It was sort of like Y2K. Everybody was panicked,” said Bobbi Buell, principal with onPoint Oncology and an expert in oncology reimbursement. “People thought it was going to be horrendous because it was such a huge change. People were afraid a lot of systems would fail.” And then it happened. September became October. Six years after the United States first intended to adopt it and 23 years after its creation, ICD- 10 was ready for prime time.


“It wasn’t as bad as they thought,” Buell said.

“Sort of like Y2K, there was not a big crash,” said Debra Patt, MD, a practicing oncologist and vice president of Texas Oncology. “Everything went on sort of flawlessly.”

Even without causing a host of disastrous problems for practices, the code set has proved to be highly complex. On one hand, it’s viewed as a necessary change that brought the United States up to speed with other countries and ushered in more precise medical record-keeping, which benefits payers and researchers. On the other, it’s seen as a headache, requiring more work for doctors and administrators and posing a hazard to the revenue cycle if coding is done inappropriately.

The linchpin of successful ICD-10 implementation, oncology professionals say, has been the EHR system. EHR systems can suggest codes and catch mistakes before billing, which will become even more important in October, when the grace period for ICD-10-specific claim denials ends.

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