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December 9, 2013

As CHCs continue working towards the October 1, 2014 deadline for ICD-10 implementation, it is apparent there are still many questions to ask. One area with which we hear CHCs are struggling is that of understanding payor progress towards readiness.

As part of implementation, one of the early tasks is to open up communication with the payors.  And we hear that many centers just don’t know what to ask. It’s really a pretty straightforward, somewhat logical approach.  Start with what do you need to know?  Certainly, you want to know if the Payor is ready.  The good news here is that the majority of payors have been in preparation mode for almost two years now, much longer than most CHCs have been preparing.  Reach out to your current connections with the payor, typically a provider representative.  That individual will probably direct you elsewhere to an IT connection who will be handling the customer service functions for the transition.

So, if the payor is ready, your next question is “When can we test with you?”  Testing of course will need to be coordinated with your EMR/PM vendor.  And that leads into the next consideration:  What kind of data or material is required to test? And “Who is going to coordinate that process?”  Because data flows through your clearinghouse, that system will also need to be part of this process. Due to these complexities, IT will be involved, but so will your billing managers/directors. We have heard from Medicare that the week of March 3-7, 2014 is currently reserved for testing. Watch your MAC communication for further instructions.

If a payor is not yet ready, you definitely want to know when they will be ready? Or even what part of the transition process are they currently working through. A payor who is not ready, should be reviewed for a contingency consideration.  What percentage of your business comes from this payor and what will a delay in ICD-10-CM potentially cost you?  Ready or not, you will want to know who to contact and how to contact that individual on a periodic basis. Add this communication to your communication plan so it doesn’t fall through the cracks.

We do know that some of this type of information is being funneled through state consortiums or a data exchange, which means you have one place to get all your data, but keep checking back for updates.

What’s interesting is that not only are you making an inquiry of the payor, but many payors are asking the same questions of you.  Will YOU be ready?  You may already have received surveys coming into your billing or revenue cycle departments asking about your readiness for ICD-10.  Make sure you take a moment to review and answer the surveys.  And if the questions are not clear, reach out to the payor for a clarification or live discussion.

So good, we have the testing question out of the way.  Now, what else do you need to consider?  Payment policies.  You know, the things that denials are made of. When will the payors be updating their local and national medical policies?  Keep a close eye on these.  We know that ICD-10 is not a one to one crosswalk, and those policies will hold the secret to many of the documentation requirements necessary to allow payment.  You can usually have access to these policies through the payor website.  Assigning a billing staff member of a clinical staff member to review these policies and compare with previous policies will be key to effective reimbursement.  We know that if an unspecified code won’t be accepted, a denial will be issued.  That means a delay in your funding, as the appeal processes through to final payment.    

Depending on the extent of the changes and updates to the payor policies, you will want to know “Is training available to your providers or to your center staff”? And if so, don’t forget to budget the cost of training.  While there may not be a cost to the program, there is a cost to the lost productivity while staff attends training.

There you have it.  The basic answers that you want to know from your payors.  Using a spreadsheet to track payors and responses will assist with organization and make the data available to all the implementation team members. 

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