It was announced last week that Home Care and Hospice would receive NO relief from ICD-10 codes being required on Home Care and Hospice claims. Earlier this year, CMS issued a notice that provided relief to physicians, stating that no penalties would occur with ICD-10 errors for 12 months following implementation, effective October 1, 2015. The National Association for Home Care and Hospice (NAHC), as well as state home care associations, has appealed to CMS to also provide relief to Home Care and Hospice, but as of now there will be no relief. Following is the response from CMS:
Thanks for your patience on this topic. CMS is not extending coding flexibility to other providers. The reason we focused on claims billed under the Part B physician fee schedule is because many physicians practice in small practices that need additional flexibility to gain experience with the ICD-10 coding set. And, claims billed under the Part B physician fee schedule are primarily paid using CPT codes and not ICD-10 codes. Other services, such as institutional services (home care & hospice are included in institutional claim regulations), are paid based on the ICD-10 codes. We have named our ICD-10 Ombudsman who will listen to issues raised by all suppliers and providers and will evaluate any specific issues that are raised during implementation. CMS’s ICD-10 Coordination Center will be actively monitoring for any problems that may develop after October 1. This center will quickly identify and initiate resolution of issues that arise as a result of the transition to ICD-10.
ICD-10 codes will be required on all claims with a date of service, on the claim, of October 1, 2015 and later. The thing that is frustrating is that a home care episode that begins in September will have all reimbursement calculated with the OASIS-C1 being calculating using ICD-9, and yet the final claim, if having a visit in October will have ICD-10 on the claim. Regardless, ICD-10 must be on the claim if there is a visit with an October date of service. The same is true for hospice. The October monthly hospice claims will require ICD-10 codes regardless of what was on the initial plan of care for the benefit period. Dual Coding should have begun with any episode or benefit period that would end October 1, 2015 or later.
Lastly, there has been recent controversy over whether or not agencies/hospices would require a signed physician order for ICD-10 codes during this period of overlapping episodes and benefit periods. There have been some comments that if you have a signed order for the ICD-9 codes that are on the initial orders for the episode/benefit period and you are simply using the conversion to ICD-10 codes for the claims that you will be fine. My concern is that the regulations are clear that you must have a signed order for all diagnoses and support that they are the codes confirmed by a physician. Needless to say, ICD-9 and ICD-10 codes are no simple conversions, in most cases. ICD-10 requires much more specificity in many cases! HPS strongly encourages agencies/hospices to get confirmation of all ICD-10 codes from a physician prior to using them on a claim to ensure that major issues do not arise if the claim is pulled for medical review.