October 10, 2015

Revised CMS Instructions Clarify ICD 10 Orders Issue

The Centers for Medicare & Medicaid Services have modified its instructions on how to handle imaging orders written before but fulfilled after the Oct. 1, 2015, ICD-10 implementation date.

In response to a request from the American College of Radiology (ACR), the Association for Medical Imaging Management (AHRA) and Radiology Business Management Association (RBMA), CMS now notes in its ICD-10 FAQ section that it is not requiring the ordering provider to rewrite the original order with the appropriate ICD-10 code for lab, radiology services or any other services or device including durable medical equipment, prosthetics, orthotics, and supplies after the Oct. 1 ICD-10 implementation date.

Products and services that require a diagnosis code on the order will use ICD-9-CM codes if written prior to Oct. 1. If the order is for a repetitive service that will continue to be delivered and billed after Oct. 1, providers have the option to use the General Equivalence Mappings (GEMs) posted on the 2016 ICD-10-CM and GEMs web page to translate the ICD-9-CM codes on the original order into ICD-10-CM diagnosis codes. 

The new instructions replace a Sept. 17 CMS notice that addressed the same issues. It was revised after the ACR, AHRA and RBMA called CMS’ attention to potentially confusing language that could have caused problems for medical imaging professionals, billing/coding staff and imaging departments.

The ACR, AHRA and RBMA acknowledge and thank Bill Rogers, MD, CMS’ ICD-10 ombudsman, Valerie Haugen, director of the Division of Provider Information Planning and Development, and Pat Brooks, senior technical advisor of the Hospital Ambulatory Payment Group, for their prompt work addressing their concerns.

CMS is actively monitoring the transition in real-time and addressing any issues that come to the ICD-10 Coordination Center. It is staffed by Medicare, Medicaid, billing, coding and information technology system experts drawn from across the CMS organization. They have the full support of the entire CMS staff to address any issue quickly and completely.

Providers are expected to have feedback on ICD-10 by mid-October to begin assessing its implementation. Most providers batch their claims and submit them every few days. Medicare claims take several days for processing, and Medicare – by law – must wait two weeks before issuing payment. Medicaid claims can take up to 30 days to be submitted and processed by states. Because of these timeframes, CMS expects to know more about the transition to ICD-10 after completion of a full billing cycle.

The following resource list was developed by CMS to help locate important contacts quickly: 

Step 1 For general ICD-10 information, see Road to 10 website.

Step 2 For Medicare claims, contact your Medicare Administrative Contractor (MAC). Your MAC is your first line for Medicare claims help. MACs cannot respond to questions about Medicaid or commercial health plans. For Medicaid claim questions, contact your state Medicaid agency For commercial or private health plan claim questions, contact the health plan directly. 

Step 3 Contact the ICD-10 ombudsman with questions at the designated ICD-10 ombudsman website. The ICD-10 ombudsman is an impartial advocate supported by a dedicated team of experts to answer your questions. Responses typically will be sent within three business days of your inquiry.

Refer to the ACR’s ICD-10 Resources Page for additional information and guidance. Be sure to check the ICD-10-CM Physician Documentation Improvement Training Podcasts. The 20 podcasts are designed for radiologists providing information to ensure proper documentation for ICD-10-CM diagnostic coding.