EDITOR’S NOTE: The more we know about the business of dermatology and the regulations which impact the delivery of services business, the more likely we are to understand the challenges they face. The following article was published in the October 2015 issue of On the Road….
The diagnosis and treatment of PRP involves patient and dermatologist. The following information was provided to On the Road… by the American Academy of Dermatology Association. The AADA is the “lobbying arm” of the AAD. For the record: the “old” Diagnostic Code for pityriasis rubra pilaris was 696.4 (ICD-9). The new ICD-10 is L44.0.
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The International Classification of Diseases, Tenth Edition (ICD-10) is a clinical cataloging system that goes into effect for the U.S. healthcare industry on Oct. 1, 2015, after a series of lengthy delays. Accounting for modern advances in clinical treatment and medical devices, ICD-10 codes offer many more classification options compared to those found in predecessor ICD-9.
Within the healthcare industry, providers, coders, IT professionals, insurance carriers, government agencies, and others, use ICD codes to properly note diseases on health records, track epidemiological trends and assist in medical reimbursement decisions.
The World Health Organization (WHO) owns, develops, and publishes ICD codes, and national governments and other regulating bodies adopt the system.
In the U.S., ICD-10 will be split into two systems: ICD-10-CM (Clinical Modification) for diagnostic coding and ICD-10-PCS (Procedure Coding System) for inpatient hospital procedure coding. These U.S.-specific adaptions conform to WHO’s ICD-10 layout while allowing for additional details found in U.S. healthcare. The U.S. took a similar approach with ICD-9-CM and ICD-9-PCS.
Increased Classification Options
The ICD-10 code list greatly expands classification options. For example, ICD-10-CM has 68,000 codes, compared to 13,000 in ICD-9-CM, according to the Centers for Medicare & Medicaid Services (CMS).
The ICD-10 conversion in the U.S. has been delayed by lobbying, politics and general opposition to the increased amount of codes in the newer set.
The U.S. has used ICD-9 since 1979. In the passing 35-plus years, supporters of ICD-10 say its predecessor has become obsolete, does not account for modern healthcare practices, and lacks ICD-10’s specificity for clinical diagnoses and medical device coding.
For example, if a patient breaks a wrist, ICD-9 does not specify whether it is the left or right wrist, while ICD-10 offers either option. ICD-10 also presents additional details on when a patient is seen by a caregiver and how an injury or disease is progressing or healing. ICD-9’s codes are based on three to five letters and numbers, while ICD-10’s are based on three to seven letters and numbers.
Ironically, ICD-10 itself is 25 years old, having first been adopted by WHO in 1990. Some countries began using ICD-10 codes in 1994.
While a further ICD-10 delay beyond Oct. 1, 2015, is not anticipated, last-minute postponements are always possible from lawmakers.
Meanwhile, the upcoming ICD-11 is under development now, and WHO will release the update in 2017.
ICD-10 Implementation
The U.S. Department of Health and Human Services (HHS) issued a rule finalizing Oct. 1, 2015 as the new compliance date for healthcare providers, health plans, and health care clearinghouses to transition to ICD-10.
The deadline was delayed to allow providers, insurance companies, and other stakeholders additional time to implement ICD-10, which restructures the diagnosis classification system with a significant increase in the number of codes, expanded code lengths, and narrative descriptions, allowing for greater granularity. Dermatology alone is moving from 9,000-plus ICD-9 codes to more than 22,000 codes in ICD-10.
The AADA has been actively engaged with CMS and the house of medicine to ensure the least onerous, most seamless and timely implementation of ICD-10. The AADA sent letters of support for four bills aimed at easing provider burden during the upcoming transition to ICD-10.
❏½ The Cutting Costly Codes Act (H.R. 2126) would prevent CMS from implementing ICD-10.
❏½ The Increasing Clarity for Doctors by Transitioning Effectively Now (ICD-TEN) Act (H.R. 2247) would provide an 18-month “safe harbor” period where physicians would be protected against rejection of claims and denial of payment based on subcode specificity.
❏½ The Protecting Patients and Physicians against Coding Act (H.R. 2652) would provide a two-year grace period where physicians would be protected from mistakes and malfunctions related to the transition to ICD-10.
❏½ The Code FLEX Act (H.R. 3018) would establish a transition period of 6 months for providers to submit healthcare claims using either ICD-9 or ICD-10 codes.
❏½ In response to pressure from physician groups, including the AADA, CMS has released additional guidance that will allow for flexibility in the claims auditing and quality reporting process as the medical community gains experience using the new ICD- 10 code set.
❏½ Medicare claims will not be denied solely on the specificity of the ICD-10 diagnosis codes provided, as long as the physician submitted an ICD-10 code from an appropriate family of codes.
❏½ Medicare claims will not be audited, based on the specificity of the diagnosis codes as long as they are from the appropriate family of codes.
❏½ Physicians using the appropriate family of diagnosis codes will not be penalized if CMS experiences difficulties in accurately calculating quality scores for PQRS, VBM, or Meaningful Use.
❏½ CMS will authorize advanced payments if Medicare contractors are unable to process claims within established time limits due to problems with ICD-10 implementation.
Were dermatologists ready for ICD-10? The answer was “Yes” – they had to be.
