Health Industry Washington Watch : Washington DC Healthcare Industry Law Firm : Reed Smith : Health Industry Washington Watch : Regulations, Medicare/Medicaid, Governmental Organizations

On May 3, 2013, CMS and the Office of the National Coordinator for Health Information Technology (ONC) are hosting a meeting to discuss electronic health records, the increase in code levels billed for some Medicare services, and appropriate coding in an increasingly-electronic environment. The meeting, which is aimed at providers, health information technology vendors, and other interested stakeholders, will address issues such as the impact of EHRs on high quality clinical care, provider efficiency and coding, and coding challenges and opportunities facing various groups, including hospitals and clinicians. Attendees may participate in person, via telephone, or web streaming.  Registration is required.

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An April 18, 2013 CMS provider call will focus on the transition to the ICD-10 code set, including implementation planning and preparation strategies. 

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The GAO has issued a report on the methodology CMS uses to calculate a risk adjustment for Medicare Advantage (MA) plans, updating an analysis in provided in January 2012. The GAO previously reported that differences in diagnostic coding between MA plans and Medicare FFS resulted in inaccurately-high MA risk scores and excessive payments to MA plans. While CMS made an adjustment for coding differences in 2010, the GAO concluded that the adjustments were insufficient. Based on an analysis of two years of data available since the GAO completed its analysis for the January 2012 report, the GAO found that the cumulative impact of coding differences on risk scores increased from 2010 through 2012, and that CMS's adjustment to risk scores to account for diagnostic coding differences was too low. The GAO estimates that as a result, at least $3.2 billion in excess payments were made to MA plans over three years. The GAO continues to recommend that CMS update its methodology to more accurately account for differences in diagnostic coding between MA plans and Medicare FFS. 
 

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In preparation for the October 1, 2014, ICD-10 code set implementation date, CMS has posted a variety of ICD-10 checklists and planning timelines for provider practices, hospitals, and payers.  CMS also has outlined suggested steps for ensuring a smooth transition to ICD-10 and preparing for potential cash-flow disruptions from claims processing delays. For instance, CMS encourages providers to process ICD-9 transactions before the October 1, 2014 deadline “to avoid facing a major backlog.”

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CMS is holding series of meetings in May and June 2013 to discuss preliminary determinations for applications for new Healthcare Common Procedure Coding System (HCPCS) codes for the 2014 update. The following are the 2013 public meeting dates:

• May 8 and 9, 2013 -- Drugs/Biologicals/Radiopharmaceuticals/Radiologic Imaging Agents
• May 29, 2013 -- Supplies and Other
• June 4, 2013 -- Durable Medical Equipment and Accessories & Orthotics and Prosthetics

Draft agendas, including a summary of each request and CMS’s preliminary decision, are expected to be posted on the HCPCS web site at least 4 weeks before each meeting.

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This post was written by Nancy Sheliga.

On March 5, 2013, the ICD-9-CM Coordination and Maintenance Committee is holding a public forum to discuss proposed code changes to the ICD-9-CM and ICD-10-CM/PCS code sets. As previously reported, CMS has scheduled implementation of the ICD-10-CM/ICD-10-PCS code sets for October 1, 2014. Accordingly, only limited code updates to capture new technologies and diseases will be considered to the ICD-9-CM and ICD-10 code sets during the March 5th meeting (regular updates to ICD-10 are scheduled to begin October 1, 2015). Both procedure and diagnosis code issues will be reviewed at the meeting. The meeting will be held at CMS headquarters in Baltimore, with phone conference lines and webcast broadcasting also expected to be available. Registration will close on February 22 or when the auditorium’s seating limit has been reached, whichever comes first.

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CMS has posted the final 2013 new and reconsidered clinical laboratory fee schedule test codes, including final payment determinations (crosswalk or gapfill).

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CMS has posted the 2013 update to the Healthcare Common Procedure Coding System (HCPCS) files. The files include the Level II alphanumeric HCPCS procedures and modifiers, long and short descriptions, and applicable Medicare administrative, coverage, and pricing data.

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CMS recently made it official that it is delaying implementation of the ICD-10-CM/ICD-10-PCS code sets until October 1, 2014. CMS has released two educational articles for providers explaining various implementation issues. The first article, “Updated ICD-10 Implementation Information,” provides an overview of the differences between the ICD-10 and ICD-9 code sets, and discusses provider preparation for the conversion. A second educational article addresses the “Partial Code Freeze Prior to ICD-10 Implementation.” The last regular, annual updates to the ICD-9-CM and ICD-10 code sets were made on October 1, 2011. On October 1, 2012 and October 1, 2013, there will be only limited code updates to capture new technologies and diseases. On October 1, 2014, there will be only limited code updates to ICD-10 code sets to capture new technologies and diagnoses, and there will be no updates to ICD-9-CM since it will no longer be used for reporting. Regular updates to ICD-10 are scheduled to begin October 1, 2015.

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On October 25, 2012, CMS is hosting a national provider call on Preparing Physicians for ICD-10 Implementation. The call will cover, among other topics: practical pointers for providers on transitioning to ICD-10 (currently set for October 1, 2014); an overview of ICD-10 implementation requirements; plans for local coverage determination (LCD) and national coverage determination (NCD) ICD-10 conversions; and national implementation issues and plans.

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On September 5, 2012, the HHS published a final rule that establishes new requirements for administrative transactions that are intended to improve the utility of the existing HIPAA transactions and reduce administrative burden and costs. Specifically, the rule adopts the standard for a national unique health plan identifier (HPID) and establishes requirements for the implementation of the HPID. Health plans generally must obtain an HPID by November 5, 2014, although the deadline for small health plans to obtain an HPID is November 5, 2015. Covered entities must use HPIDs in the standard transactions on or after November 7, 2016. HHS estimates that implementing the HPID will result in net savings of approximately $1.3 billion to $6 billion for the entire health care industry over 10 years. In addition, the rule establishes a data element that will serve as an “other entity identifier” (OEID), or an identifier for entities that are not health plans, health care providers, or individuals, but that need to be identified in standard transactions. The rule also specifies the circumstances under which an organization covered health care provider must require certain noncovered individual health care providers who are prescribers to obtain and disclose a National Provider Identifier (NPI); the compliance date is for this provision is May 6, 2013.

The rule also postpones the implementation date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding, and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD–10–PCS) for inpatient hospital procedure coding, from October 1, 2013 to October 1, 2014. This delay is intended to give covered entities more time to prepare and fully test their systems to ensure a smooth transition to these new code sets. CMS notes that any extension of the current limited freeze on code updates based on the delay adopted in the rule will be discussed and decided by the ICD-9-CM Coordination and Maintenance Committee.

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CMS is holding meetings July 16 and 17, 2012 to receive public input on the appropriate basis for establishing payment amounts for new or substantially revised HCPCS codes being considered for payment under the Medicare clinical laboratory fee schedule for 2013. The deadline for registration of presenters and submission of presentations is July 6, 2012.

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On April 17, 2012, HHS published a proposed rule that would to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition (ICD-10) diagnosis and procedure codes from October 1, 2013 to October 1, 2014. HHS notes that many provider groups have expressed concerns about their ability to meet the 2013 compliance date; the extension is intended to give covered entities more time to prepare and fully test their systems to ensure a smooth transition to these new code sets. This compliance delay would be accompanied by an extension of the limited freeze on updates to the code sets. The rule also would implement section 1104 of the ACA by establishing new requirements for administrative transactions that are intended to improve the utility of the existing HIPAA transactions and reduce administrative burden and costs. Specifically, the rule would: adopt a standard for a unique health plan identifier (HPID); adopt a data element that would serve as an “other entity” identifier (OEID) for entities that are not health plans, health care providers, or “individuals” that need to be identified in standard transactions; and specify the circumstances under which an organization covered health care provider must require certain noncovered individual health care providers who are prescribers to obtain and disclose a National Provider Identifier (NPI). HHS estimates that the proposed changes would save health care providers and health plans up to $4.6 billion over the next ten years. Comments on the rule will be accepted until May 17, 2011.

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HHS Secretary Kathleen Sebelius has announced that “HHS will initiate a process to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10).” Under the January 2009 final rule adopting ICD-10 as a standard, the compliance date was set for October 1, 2013; CMS has not yet released its new compliance date. The implementation delay is a result of concerns in the provider community regarding the administrative burdens associated with compliance.

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CMS has announced the following schedule of public meetings to discuss preliminary coding and payment determinations for new Healthcare Common Procedure Coding System (HCPCS) applications:

• May 8, 2012: Drugs/Biologicals/Radiopharmaceuticals/Radiologic Imaging Agents
• May 9, 2012: Supplies and Other
• June 5, 2012: Orthotics and Prosthetics and Durable Medical Equipment and Accessories

Registration is required.  CMS's preliminary decisions on the HCPCS applications will be posted on the CMS HCPCS web site at least 4 weeks before each meeting.

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On February 16, 2012, CMS is hosting a Special National Provider Education Call regarding Medicare fee-for-service (FFS) implementation of HIPAA Version 5010 and D.0 transaction standards. The call will focus on addressing recommendations made by the industry as well as outstanding fixes impacting the Part A and Part B Version 5010 transition.  Registration is required. 

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CMS has posted the 2012 ICD-10-CM code updates (which are replacing the ICD-9-CM diagnosis codes) on its website. CMS previously released the 2012 ICD-10-PCS (procedure) files.

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CMS has compiled resources for the health care industry as they prepare for the transitions to Version 5010 HIPAA electronic health transactions standards on January 1, 2012 and the ICD-10 for medical diagnosis and inpatient procedure coding on October 1, 2013. Most recently, CMS has released a series of “Implementation Handbooks” to assist small and medium provider practices, large provider practices, small hospitals, and payers with the transition to ICD-10. 

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CMS has issued instructions on the CY 2012 update to the Medicare Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) fee schedule. Among other things, the transmittal provides for a 2.4% increase to the DMEPOS fee schedule; updates the gap-filling methodology for pricing of new DMEPOS; and provides instructions related to codes and modifiers, DMEPOS competitive bidding product category codes, and pricing updates. 

Update:  The fee schedule files are now available.

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Today CMS released the 2012 update to the Healthcare Common Procedure Coding System (HCPCS) files.  The files include the Level II alphanumeric HCPCS procedures and modifiers, long and short descriptions, and other related data.

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