10 Tips For a Smooth Transition into ICD-10

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William Rodgers , M.D. Has been appointed the official ICD-10 ombudsman appointed by the CMS. Also Sue Bowman of the AHIMA and Nelly Leon-Chisen of the AHA provide several tips for the ICD-10 transition.

Official Ombudsman Appointed by CMS

ICD-10 Calendar

The ICD-10 deadline is exactly one month away from today, and providers are more anxious than ever. Last Thursday, the Medicare Learning Network hosted a National Provider Call with information and tips for success for all those involved in the big transition.

During the call, the Centers for Medicare and Medicaid Services (CMS) Acting Administrator Andy Slavitt announced that they have appointed William Rogers, M.D. as the official ICD-10 ombudsman and a “one-stop-shop” resource for providers. The role will involve assessing ICD-10 issues and triaging the situations accordingly. Rogers has been with CMS since 2003, serving as Director of the Physicians Regulatory Issues Team.

The “Countdown to ICD-10” agenda included guidance from Sue Bowman of the American Health Information Management Association (AHIMA) and Nelly Leon-Chisen of the American Hospital Association (AHA).

They provided several tips, emphasizing that the date of service is the “key driver” in the ICD-10 transition:

  1. The code is determined by the date of service, not the billing date
  2. The date of service is defined as the date of discharge for inpatient facilities
  3. Claims submitted for dates of service on or after October 1st must use ICD-10 codes
  4. Claims submitted for dates of service before October 1st must use ICD-9 codes
  5. If a claim is submitted after the deadline, but the date of service is prior to October 1st, it should be coded using ICD-9
  6. Claims cannot include both ICD-9 and ICD-10 codes
  7. Dual coding cannot occur
  8. Any claims for dates of service after Oct. 1st with ICD-9 codes will be rejected
  9. For an ICD-10 code to be valid, the full number of characters required for that code must be used
  10. Unspecified codes are acceptable, and sometime necessary, to use

Dr. Mandy Cohen, Chief of Staff at CMS, reiterated the flexibility that CMS will be offering for ICD-10. For one year after the transition occurs, Medicare will not audit ICD-10 codes as long as a valid code from the correct family is used. As previously explained by CMS, the first three characters of the code differentiate a family of codes.

One item we would like to remind the healthcare community about is that CMS is not flexible regarding the start date of submitting ICD-10 related claims. If submissions are received before the October 1st transition date that contain ICD-10 codification, they will be rejected. So, although the industry is anxiously awaiting implementation of ICD-10, there are no rewards for filing submissions using ICD-10 any earlier than October 1.

CMS also discussed results from their final round of end-to-end testing of ICD-10, which occurred July 20-24th. Testing was done on about 1,200 participants, including Medicare fee-for-service providers, clearinghouses, and billing agencies. 1.8% of the claims were rejected due to invalid submission of an ICD-10 code and 2.6% of the claims were rejected due to invalid submission of an ICD-9 code, but 87% of the test claims were accepted. The acceptance rate was similar to that of previous testing rounds from January and April, and most participants were able to successfully submit their test claims, suggesting that CMS systems will be able to accept claims with ICD-10 codes.


PrognoCIS EMR is ICD-10 compliant and prepared for users. The easy to use interface enables users to quickly find the code they need and populate it into the patient chart. If an ICD-10 code is not filled in, the software will prompt users to add them in with an alert. All lab & radiology tests, as well as e-prescriptions, will include ICD-10 codes. To learn more about the PrognoCIS ICD-10 solution, visit our ICD-10 Hub or click here to schedule a live demonstration with one of our experts: PrognoCIS Demo.

Author: Apoorva Anupindi

Editor’s Note: Although their are four states whose CMS agencies are temporarily using ICD-9 codes for their internal processes, on Oct 1, 2015, PrognoCIS EHR will codify as ICD-10 in every state in accordance with current clearing house guidelines. The “crosswalk” retro-coding is handled entirely at the state CMS level and does not call for claim submissions in ICD-9. PrognoCIS EHR is prepared for the Oct 1, 2015 change in all states.

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