By Michele Hibbert-Iacobacci, CMCO, CCSP, Vice President of Information Management and Support at Mitchell International
On March 31, 2014 the ICD-10-CM/PCS (International Classification of Diseases-10th Revision, Clinical Modification and Procedural Coding System) implementation was delayed in the United States due to the Senate approved a bill (H.R. 4302). This update to the obsolete ICD-9-CM/PCS was a requirement in the Health Insurance Portability and Accountability Act (HIPAA) for all covered entities. Workers’ compensation has been excluded as an industry that is not covered under HIPAA (non-covered entity); however, the providers submitting the medical bills to workers’ compensation payers are covered entities. By proxy, the workers’ compensation industry needed to prepare to accept ICD-10-CM/PCS by the implementation date of October 1st 2014 and the majority of payers and vendors were ready to process bills by that date.
The effects of ICD-10 implementation delays are widespread for the workers’ compensation medical payment industry due to the guidance that is provided, for a majority of cases, at the state level for workers’ compensation payments. Since each state is its own entity for payment rules, each has different policies on the timeline of acceptance for either ICD classification system, making the delay even more complicated. Workers’ compensation has always depended on what providers will submit for payment on medical bills and in electronic transactions.
It was originally anticipated that workers’ compensation would experience different varieties of bill presentment, including bills submitted with both codes and ICD-9 codes being submitted well after effective dates. Now, the industry must consider that there will be more bills submitted after the prior effective date in 2014 containing ICD-10-CM/PCS codes and evaluate how this should be handled. I suspect that most payment system vendors considered this as a possibility when developing bill review systems aimed toward the 2014 date and therefore, created edits that are versatile enough to provide insight when inappropriate codes are submitted.
The differences in guidelines from state to state will be the most challenging to overcome as many states will need to reverse changes and effective dates of ICD-10-CM/PCS due to the delay. Making changes in statutes for the majority of states will require legislative involvement and further the cost of implementation in workers’ compensation. The delay to 2015 will also postpone programs that were instituted to monitor the new code set and anticipated benefits of tracking risks to injured employees. On the other hand, the use of ICD-10-CM/PCS will provide improved financial and administrative performance due to the added descriptions and codes that benefit the review of these claims. The sooner ICD-10 is adopted the sooner organizations will reap these benefits.
The ultimate benefit of the delay is the additional testing and implementation timeframes for payers that were not in a ready state for 2014. Additional time for testing, communicating to providers and education (external/internal) enhances the readiness for the new date. The downside is the cost – for organizations that were prepared for the 2014 implementation, staff has been added and enhanced with testers, trainers and coders. As a result, staffing levels will need to be maintained that may have only been budgeted for shorter timeframes. In addition, electronic health record and standard expectations for reporting requirements will change from state to state, potentially costing the taxpayers more money than anticipated. Overall, the cost to implement ICD-10 for the 2015 effective date is higher and many companies did not plan on the additional timeline.