by Max Gottlieb
It’s already September. Summer is almost over. October 1 is just over the horizon, followed quickly by Halloween, a far less frightening date. For most of the healthcare world, October 1 marks the switch from ICD-9 to ICD-10. However, as far as the actual people implementing the code are concerned, October 1 is not the most important date. That date has already passed.
Hopefully you didn’t miss August 3rd, but if you did, I’ll try to explain the importance of it. August 3rd marked 60 days until October 1st and, since home health functions in the Medicare system on a 60-day cycle, any set of reimbursements after August 3rd need to be dual coded in ICD-9 and ICD-10. Unprepared agencies will face a decline in reimbursements following the switch—not to mention a major headache with the backlog that will ensue.
According to CMS, there are three factors that affect how ICD-10 must be used in billing Requests for Anticipated Payments (RAPs) and final claims that span the October 1 date:
1. The claim "from" date (episode start date)
2. The OASIS assessment completion date (M0090 date); and
3. The claim "through" date (episode end date)
Let’s break that list down a little bit:
1. The claim "from" date is describing the RAPs. Since RAPs are billed at the beginning of the cycle they will need to be entered using the old ICD-9 codes. So for any RAPs filed on or after August 3 you will need to stick to the old coding.
2. Since OASIS assessments must be completed within 5 days of start of care, the assessment completion (M0090) date determines which type of coding is appropriate. In cases where episode start dates are before October 1, and the M0090 is also before October 1, ICD-9 codes will be used on OASIS to determine the payment group code. For episodes where care begins before October 1 but, because of the five-day completion window, the M0090 date falls after October 1, you will need to use ICD-10 codes.
3. Since the Final Claim is billed at the end of the episode, which will fall somewhere after October 1, it will need to be entered using the new ICD-10 codes. The complicated part of this whole thing is that ICD-10 coding will not be accepted until October 1. This means that although Medicare billing requires the ICD-9 codes pre-October 1 on RAPs, you will need to match the diagnosis to ICD-10 codes when you enter the Final Claim.
A recent survey that questioned over 200 agencies found that most said they were not ready for the shift. That’s a little bit alarming, but there’s no reason you shouldn’t start getting ready for the change if you haven’t already. If there is no ICD-10 coding present in your recent episodes, now is the time to start to avoid more hassle in the near future.
Max Gottlieb is the content manager for Senior Planning in Phoenix, Arizona. Senior Planning provides free assistance to seniors, helping them apply for benefits and find a senior living situation that best fits their needs.