CLN Article

Federal Insider

Grace Period Ends for ICD-10 Transition

This month the Centers for Medicare and Medicaid Services (CMS) grace period for ICD-10 codes comes to an end, marking another step in the ICD-10 medical coding system transition that CMS implemented in October 2015. All claims with dates of service of October 1, 2015, or later must now be submitted with a valid ICD-10 code and the old ICD-9 codes will no longer be accepted. ICD-10 allows much greater specificity for diagnosis codes, and laboratories must be vigilant in working with physicians to ensure that lab requisitions are coded correctly.

From October 1, 2015, until October 1, 2016, CMS allowed a grace period whereby codes would be accepted as long as they came from the right code family. CMS has been processing and not auditing ICD-10 codes under this provision. A family of codes are clinically related and share the same three-character category. They may be disease-specific, such as the code for Crohn’s disease, K50. However, with the grace period over, using the correct family of codes is not enough. In this example, Crohn’s disease of the small intestine with intestinal obstruction is K50.012, while Crohn’s disease, unspecified, without complications is K50.90. Medicare review contractors will also now review the differences between codes in the same family and could deny a claim that misses the correct level of specificity.

At the same time, CMS wants providers to use less precise unspecified codes when appropriate, according to a question-and-answer published in August. For example, a provider may determine a diagnosis of pneumonia but not the specific type. CMS notes that it is inappropriate to select a specific code that is not supported by the medical record or to conduct medically unnecessary diagnostic testing to determine a more specific code.

AACC Raises Questions About Veterans Affairs Proposed Rule

AACC is questioning a Department of Veterans Affairs (VA) proposal that would allow advanced practice registered nurses to “perform, supervise, and interpret” laboratory testing. The proposal goes beyond current clinical practice in which certified nurse practitioners order and interpret laboratory tests.

In a letter to the VA, AACC wrote that “although AACC agrees that nurse practitioners are invaluable members of the healthcare team, their education and training covers a breadth of medical disciplines and therefore does not delve into the depths of scientific concepts underlying clinical laboratory testing. Permitting [certified nurse practitioners] to serve in a supervisory capacity or as testing personnel—without first assuring they have the requisite experience, training, and skills—could lead to unnecessary medical errors that may jeopardize patient care.”

The association is recommending that the VA remove these provisions from the proposed rule, as well as take steps to work with the laboratory community to discuss its specific needs while protecting quality care for veterans.

Growth of Telehealth Tied to Reimbursement Changes

According to a report from the Department of Health and Human Services (HHS), telehealth increases access to care, improves health outcomes, and potentially reduces healthcare costs, but a patchwork system of regulation and reimbursement limits all of these potential benefits. The August report to Congress, “E-health and Telemedicine,” outlined several areas currently limiting telehealth expansion, including: variability in telehealth coverage among payers; state licensure requirements for clinicians and the administrative burden they impose; credentialing and privileging issues; and gaps in access to affordable broadband connections.

HHS estimates that 61% of healthcare institutions in the U.S. currently use some form of telehealth. Business-wise, the most recent figures, from 2013, show that the market for telehealth generated annual revenue of $9.6 billion, 60% higher than 2012. HHS emphasized in the report that “telehealth appears to hold particular promise for chronic disease management.” However, most telehealth services for chronic conditions are limited to asynchronous monitoring.

Currently, 48 state Medicaid programs provide some level of telehealth coverage, while 68% of large employers plan to cover telemedicine consultations by 2017. HHS said it is looking for ways to expand coverage for telehealth using provisions under the Medicare Access and CHIP Reauthorization Act of 2015 and through the Medicare Advantage program.