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Like it or not, ICD-10 is here - what practices need to know



After much debate and years of delay, the October 1, 2015, implementation date for ICD-10 has finally arrived. While concerns remain as to the preparedness of physician practices for this monumental transition, the full impact of the ICD-10 conversion will likely not be felt for several weeks or until the first payment remittances are received.

CMA resources


As the implementation unfolds, there likely will be unanticipated hurdles that need to be overcome. The California Medical Association (CMA) has a number of resources to help members prepare.

  • CMA ICD-10 Tip Sheet: In an effort to help practices navigate the transition, CMA has published an FAQ to help practices survive ICD-10 implementation.
  • ICD-10 Transition Guide: This guide will help practices of all sizes successfully make the switch to the new ICD-10 coding system. It answers frequently asked questions and includes CMA’s “ICD-10 Transition Preparation Checklist” to help ensure the transition is a smooth one. The guide is FREE to members only.

  • One-on-one assistance: If you are having trouble with claims being denied or delayed—whether it’s related to ICD-10 or not—CMA is here to help. Members can call on our practice management experts for one-on-one help with payment, billing and contracting problems. This is a FREE service to CMA members only.

  • CMA ICD-10: An Overview webinar: Presented by AAPC, this on-demand webinar is available free to members on the CMA website. The previously recorded webinar is intended as a final review for those who have a base knowledge of ICD-10. Nonmembers can access the webinar for $99. To download, click here.

  • Discounted ICD-10 education and training: CMA has partnered with AAPC to offer discounted specialty-specific documentation training for physicians (three-hour, online courses). For more information on the 21 different specialty-specific documentation courses offered, visit www.cmanet.org/aapc (be sure to login to the CMA website to access member pricing).

  • ICD-10 news alerts: The CMA website allows registered users to create custom content alerts on the topics that are of interest to you. Once signed up, you will be notified any time there is new content posted in one of your areas, including ICD-10 issues. To sign up, go to www.cmanet.org and visit your account dashboard, click on “My Alerts,” then select “ICD-10."

The above resources are all accessible on CMA’s ICD-10 resource page at www.cmanet.org/icd10.

Claim submission alternatives

The Centers for Medicare and Medicaid Services (CMS) recently announced it is offering claim submission alternatives for providers who have difficulties submitting ICD-10 claims. Specifically, if your practice has been unable to complete the necessary systems changes or you are having issues with your billing software, vendor(s), or clearinghouses, the following claim submission alternatives are available:

  • Free billing software
  • Provider internet portals
  • Direct data entry
  • Paper claims (in limited circumstances) – Providers must apply for and meet all of the following requirements to qualify for a waiver of the Administrative Simplification Compliance Act provisions:
    • Your software or software vendor is not ICD-10 ready, and it will cause a financial hardship for you to switch to another software or vendor; and
    • Your Medicare Administrative Contractor’s provider Internet portal does not support electronic claims submissions; and
    • It would cause financial hardship for you to procure the services of a billing agent/clearinghouse.

    For more information, visit Medicare Learning Network Matters Number SE1522.

    Please note that while CMS is offering claim submission alternatives, they still require the use of ICD-10 code sets on and after October 1, 2015. Also, the claim submission alternatives offered above only work for Medicare claims and will not work for other claim types.

    What does the CMS “flexibility” really mean?


    In early July, CMS announced that for a period of one year, it will allow for flexibility in the claims payment, auditing and quality reporting processes as the medical community gains experience using the new ICD-10 code set.

    CMS issued an FAQ in early July and updated the FAQ with clarifying guidance on July 22. However, CMS issued updated guidance on September 22 that included additional questions and answers.

    So, what does the CMS flexibility really mean? First, the ICD-10 implementation date of October 1, 2015, has not changed. Claims submitted with ICD-9 codes on or after that date will be rejected. Additionally, the guidance only applies to fee-for-service Medicare claims and does not extend to commercial, Medi-Cal, Medicare Advantage or workers’ compensation claims.

    Claim denials: According to the CMS guidance, as long as the code submitted is from the right family of codes, is coded to the maximum level of specificity, and as long as there isn’t a local or national coverage determination that requires a specific code, the Medicare claim will be processed and will not be audited. If, for example, you submit a valid five-character code, you wouldn't be audited simply because you selected the wrong fifth character. This flexibility will continue for a period of 12 months.

    Quality reporting: Physicians also will not be penalized under the quality reporting programs for errors related to the additional specificity of the ICD-10 diagnosis code, again as long as a code from the correct family of codes is used.

    Advance payments: If Medicare contractors are unable to process claims within established time limits because of administrative problems, such as contractor system malfunction or implementation problems, advance payment may be available to keep resources flowing to physician practices.

    ICD-10 ombudsman: CMS has set up an ombudsman, Dr. William Rogers, to monitor the implementation of ICD-10 and to help triage physician and provider issues related to the transition. Inquiries can be submitted via email to ICD10_Ombudsman@cms.hhs.gov.

    For more information on the CMS guidance, see the updated FAQ.

    Workers’ compensation claims transitioning to ICD-10 on October 1

    Regulations requiring the transition to ICD-10 by the California Division of Workers’ Compensation were recently approved. Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the implementation of ICD-10 would have been exempt for workers’ compensation programs unless required under state regulation. With approval and publication of the new regulations, California will now require use of ICD-10 for workers’ compensation claims on and after October 1, 2015.

    CMA will continue to provide practices with updates and important information through the ICD-10 transition webpage at www.cmanet.org/icd10.

    If you need further assistance, members may contact CMA’s reimbursement help line at (888) 401-5911 or economicservices@cmanet.org.



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