Liles Parker PLLC
(202) 298-8750 (800) 475-1906
Washington, DC | Houston, TX
San Antonio, TX | Baton Rouge, LA

We Defend Healthcare Providers Nationwide in Audits & Investigations

Novitas Reminds us of the Impending ICD-10 Transition Date: October 1, 2014

(February 7, 2014):  The upcoming ICD-10 transition is only a little more than six months away! Earlier today, Novitas Solutions, Inc. (Novitas) re-issued the Centers for Medicare and Medicaid Services’ (CMS’) article on “Medicare Fee-For-Services (FFS) Claims Processing Guidance for Implementing International Classification of Diseases, 10th Edition (ICD-10).” A copy may be found here. As most health care providers, suppliers, and billers are aware, effective October 1, 2014, all individuals and entities covered under the Health Insurance Portability and Accountability Act (HIPAA) are required to use the ICD-10 codes to code claims that fall under the ambit of HIPAA.

October 1, 2014 is a total transition date. That is, ICD-9 codes will no longer be accepted for any claims with dates of service or discharge on or after October 1, 2014. Notably, a claim cannot contain both ICD-9 and ICD-10 codes. Claims that continue to use ICD-9 codes for health care services rendered on or after October 1, 2014 will be returned to the respective provider as unprocessable. Until then, all claims for dates of service preceding October 1, 2014 must use ICD-9 codes, making the transition rather abrupt. All trials with ICD-10, therefore, must be worked out with internal teams and business trading partners in the interim.

Of course, the rules surrounding ICD-10 codes are very different and the codes are much more specific as compared to ICD-9. The concern for all those subject to HIPAA is how to quickly and smoothly make the transition from ICD-9 to ICD-10. CMS recognizes the daunting nature of this task and has prepared various educational materials for providers. CMS has also proffered recommendations, including the following:

  • Establish an ICD-10 transition team or project coordinator;
  • Develop a plan for making the ICD-10 transition;
  • Determine how the ICD-10 transition will affect your organization;
  • Review how ICD-10 will affect clinical documentation requirements and electronic health record (EHR) templates;
  • Communicate the plan, timeline, and new system changes and processes;
  • Secure a budget;
  • Talk with your payers, billing and IT staff;
  • Coordinate your ICD-10 transition plans; and
  • Talk to your trading partners about testing.

In regard to training, the American Health Information Management Association (AHIMA) recommends that training begin no more than six to nine months before the October 1, 2014 transition deadline. The time is now.

Healthcare LawyerLorraine Ater, Esq. is a health law attorney with the boutique firm, Liles Parker, Attorneys & Counselors at Law.  Liles Parker has offices in Washington DC, Houston TX, McAllen TX and Baton Rouge LA.  Our attorneys represent health care professionals around the country in connection with government audits of Medicaid and Medicare claims, licensure matters and transactional projects.  Need assistance?  For a free consultation, please call: 1 (800) 475-1906.



ICD-10 Will be Here Soon. Is Your Practice Ready?

Is your practice prepared to make the transition to ICD-10?(June 14, 2013):  Despite experiencing a couple of false starts, it now appears that ICD-10 is here to stay, and there are expected to be further.  Why are providers being required to transition over from ICD 9?  Unfortunately, ICD-9 is considered to be outdated and some its categories are literally beyond their useful capacity.  Regardless of your feelings regarding transition, many experts believe that the move the ICD-10 will be one of the biggest changes in healthcare to occur in the last 30 years. Frankly, most practice managers and treating providers across the United States simply don’t know where to start with the ICD-10 implementation process. The clock is ticking. According to the CMS timeline, health care providers should already be conducting internal claims testing.  Have you taken this first step?  From our discussions with providers, it appears that the average practice today does not even know the first step to getting started with ICD-10 implementation.

I.     We Can Learn from the Mistakes of Early Adopters of ICD-10:

Notably, the United States and Italy are the only industrialized countries in the World not using ICD-10. Many countries have been using ICD- 10 for almost a decade.  Their experiences will prove invaluable as our providers move to ICD-10. Their advice?

  • Don’t wait to the last minute to begin your preparations. Prepare early.
  • Now is the time to examine your documentation practices.  Will they be sufficient to permit the detailed coding required by ICD-10?
  • The failure to fully prepare will directly hit your bottom line.  In 2014, ICD-10 will be one of the cornerstones for getting paid.

II.  How Long Does it Take to Transition Over to ICD-10?

An ICD-10 transition expert we work with, Lisa Asbell, R.N., estimates that it can take a practice up to 500 hours to transition properly. . Lisa is the President of TrainRX.  Her transition training website is located at: Notably, Lisa has estimated that If you were to start today and break that down over the next 16 months, chances are you will be okay with the clock runs out on October 1, 2014. If you don’t get serious about transition now, there is a chance that your practice won’t survive the transition.

III.  How Do You Get Started?

What are the first steps to get started:

  • The first thing you need to do is convert your most frequently used diagnosis codes from ICD-9 to ICD-10.
  • Next, perform chart reviews to see if all of the newly required documentation elements for ICD-10 are in the chart. Is there enough information for you to submit the correct ICD-10 code? If there is, great that is a good start. If you don’t have enough information, then you know that your providers will need more education.  While is only the first of many, many steps in transitioning over to ICD-10, it’s a solid start!

IV.   Can You Handle the ICD-10 Transition Without Help?

Depending on when you initiate your transition and level of coding expertise in your practice, you may or may not need outside assistance. On estimate has placed the overall cost of transition at $60,000-$80,000 for a five provider practice. That number includes training, lost productivity and the expenses associated with hiring part-time staff during the period of transition. It does not include any software upgrades or hiring a transition Project Manager. The sooner you begin the process, the lower your overall transition costs will be.

Robert W. LilesHealthcare Lawyer serves as Managing Partner at Liles Parker.  Liles Parker is a boutique health law firm with offices in Washington, DC, Baton Rouge, LA, Houston, TX and McAllen Texas.  Robert has extensive experience representing health care providers in the areas of regulatory compliance.  Should you need assistance or have questions regarding a health law regulatory issue, call Robert for complimentary consultation.  He can be reached at: 1 (800) 475-1906.