HBMA Invited to Testify Before NCVHS

Solutions discussed when converting from ICD-9 to ICD-10

LAGUNA BEACH, Calif. – July 10, 2012 --  The Healthcare Billing & Management Association (HBMA) is keenly aware of the difficulties involved in making the conversion from ICD-9 to  ICD-10 CM.  This is why HBMA, the premiere non-profit educational resource and advocacy group representing third-party medical billing companies and billing professionals, was invited to Washington to testify before The National Committee on Vital and Health Statistics (NCVHS), Standards Subcommittee.

NCVHS is the National Committee charged with advising the Secretary of Health and Human Services on all HIPAA related matters.

HBMA is concerned that unless the “lessons learned” from 5010 materially inform and affect the implementation of ICD-10 CM, the economic stability of America’s healthcare reimbursement systems will be at risk and could be severely compromised, affecting provider financial viability and patients’ access to care, a concern we know CMS acknowledges.

Holly Louie, CHBME, Chair of the HBMA ICD-10/5010 Committee presented the association’s views on “lessons learned” from the 5010 implementation and how those lessons can and should be applied to avoid problems with ICD-10 implementation.

In Louie’s testimony, she said, “HBMA believes that we MUST learn from the mistakes that were made in transitioning from 4010 to 5010, and undertake the transition from ICD-9 CM to ICD-10 CM in a way that demonstrates we learned those lessons.”

“If all we accomplish as a result of this notice of proposed rulemaking (NPRM) is moving the date from October 1, 2013 to October 1, 2014 or some later date, then we will have failed to make the changes that will be necessary to ensure that the new date is final and the transition is successful.  More importantly, we will merely be delaying the likelihood for payment disruptions and patient access to care problems from 2013 to 2014.”

In the view of HBMA, central among the shortcomings in the 5010 transition was the lack of a standard definition of what it meant to be “5010 ready.”

HBMA strongly recommends that the following be adopted in conjunction with the delay:

1. CMS should adopt and enforce a uniform definition of ICD-10 CM “ready”.   “ICD-10 CM ready” should mean, at a minimum, the complete end-to-end testing of 837 and 835 transactions in full production have successfully been accomplished.  Any maps or crosswalks used by a health plan to adjudicate a 5010/ICD-10 CM compliant claim must be publicly available and the diagnosis code(s) used for claims adjudication are reported. 
   

2. Any entity (billing company, software vendor, clearinghouse health plan, provider, etc.) that cannot document that they meet this definition of ready, should be prohibited from publicly asserting that they are ICD-10 CM “ready.”  Entities improperly asserting ICD-10 CM readiness would be subject to fines and penalties. 
   

3. HBMA recommends that health plan coverage policies be published by October 1, 2013.  This would allow adequate time for education and training, programming, data analysis and other preparations for ICD-10 CM. 
   

4. HBMA recommends that CMS create a national bulletin board where all health plans can enter their name, date ready for testing, date ready for production, links to any ICD-9 CM/ICD-10 CM maps or crosswalks the plan may use during the transition and contact information for each along with the site where any companion guides can be located and downloaded.  CMS could use this national bulletin board as a means of tracking and publicly reporting health plan readiness.  Providers would know ahead of time which plans were on-schedule and those that were behind.  Consumers would also be able to ascertain whether their plan was on schedule and make insurance purchasing decisions accordingly. 
   

5. HBMA recommends that the new date be adopted, subject to the identification of specific, verified readiness criteria for providers and insurers.  If these deadlines were not met by health plans due to blatant disregard for making the necessary changes, CMS has the authority to impose penalties for failure to be HIPAA compliant.  CMS should be prepared to exercise – and announce its intention to exercise – the penalty imposing authority for failure to meet the various milestones.
   

HBMA members process both physician and non-physician provider claims as well as hospital claims integral to the U.S. healthcare delivery system.  A typical HBMA member processes approximately 350,000 – 400,000 claims per year, although some companies do much more.  HBMA’s expert remarks were made on behalf of the membership with the goal of making this transition as smooth as possible for the entire medical community.