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ICD-10 concerns remain, two weeks to go

September 17, 2015
by Lisette Wright
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With less than two weeks to go on transitioning to ICD-10, our industry continues to struggle with understanding what is happening, why, and the impact to clients, providers and paychecks. Let’s address some of the top concerns I am hearing across the nation when I talk with providers, organizations and state regulators:

1. Misinformation Abounds. State agencies, payers and others tell providers to use ICD-10 codes beginning  October 1, 2015, but they cannot articulate the action items required for providers regarding precertifications, prior authorizations or random discrepancies. Some states are issuing lists of codes they will pay for under reimburseable services. These lists are short-sighted, leave out critical diagnoses in our industry, or are highly restrictive in nature. EHR vendors are reporting that despite their large education campaigns, many customers still believe ICD-10 does not apply to them.

2. Code Source: X-codes? Tabular index? Yes, state governments are asking questions about these sources, which is both scary and encouraging at the same time. It is imperative that we utilize all possible codes available to us moving forward, such as the X-codes, or the Intentional Self-Harm codes. If we do not diagnose the X-codes, how are we to track the severity of suicide attempts over time in a medical record? Writing it down in the text or narrative portion of a chart is simply not good enough because it will be overlooked in data analysis. With health information technology, we can pull diagnosis reports and see the trend in suicide attempts, means and lethality over time. How cool is that? But we have to input the code in the first place if we hope to get a report on it! Finally, the only official CMS-approved source for ICD-10 CM codes is the CDC/NCHS Tabular Index (see link below). That’s it. Getting your diagnoses codes anywhere else can be very risky.

3. Crosswalks:  Why do people want crosswalks or even books or apps that itemize the recommended crosswalked codes? As I frequently discuss, all crosswalks are fallible including the Centers for Medicare and Medicaid Services’ GEMS. Many crosswalks map to “unspecified” ICD-10 codes which puts providers  and clients at risk. There is an easy answer, however: Get the Tabular Index, become familiar with your population’s diagnoses, and assign ICD-10 CM codes to your clients. Note that it does require you to do your homework and not use “cheat sheets” in lieu of your sharp clinical mind.

4. ICD-10 Compliance: Too many believe, “All we have to do is pick the right code, and all is well.” Our industry is lacking on the compliance front— from not being accountable to the Guidelines for Coding and Reporting to overutilizing unspecified diagnoses. Payment models and policy reform will increasingly provide scrutiny to our documentation elements and will require us to substantiate diagnoses, treatment and progress. Having an ICD-10 compliance program to help with clinical documentation improvement would be advised.

5. Education: Despite accrediting bodies mandating the teaching of the ICD-series starting in 2016, our entire industry is ill-versed in all that is required to be ICD-10 compliant. If the educators are not educated, then how can our graduate students get properly trained?



Lisette Wright

IT Consulting for Health and Human Services

Lisette Wright



Lisette Wright, M.A., LP has over 20 years of experience in the healthcare...

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