ICD-10 Compliance for Mental Health
by Leigh-Ann Renz, 1/9/14 (revised & updated 6.19.15)
Mental & Behavioral Health Practices Need to Plan Now for ICD-10!!
ICD-10 is here: although the official deadline is not until October 1, 2015, some hospitals and medical practices have been preparing for the change for years. This transition is huge and cannot be put off until the last minute! You must get up-to-speed on ICD-10 and implement a compliance plan now.
What is ICD-10 and why is it such a big deal?
HIPAA requires that all claims (including insurance and Medicaid/Medicare) be billed with ICD diagnosis codes. While the US has been using ICD-9 codes for decades, other industrialized nations have been using ICD-10 since the early 1990s. The US is now making the transition to ICD-10, and it means that medical codes will be increasing from approximately 12,000 to 68,000. This is because an ICD-10 code offers greater specification and detail: an ICD-9 code often cannot be directly converted into one ICD-10 code; there are multiple options for conversion, which significantly increases the number of available codes.
Industry experts are warning that this complexity means that medical practices need to have six months of cash reserves to get through the transition. They warn that productivity will extensively decrease after ICD-10 because providers will have increased documentation responsibilities and billing / coding staff will take longer to process claims: coding experts say that 20-25 charts could be processed per hour using ICD-9, but this will translate to only 8-10 charts using ICD-10.
ICD-10 and Mental Health
Because mental health is only a small portion of the 68,000 new ICD-10 codes, it would be tempting to assume that this isn’t a big deal for our industry and put it off until the last minute. But 1) the challenges presented to the rest of the medical industry should be expected for mental / behavioral health and substance usage; and 2) the recent move from DSM-IV to DSM-5 makes things even more complicated for our industry.
Is ICD-10 Necessary If You Only Accept Self-Pay Clients?
Even if your practice is entirely self-pay (and you don't provide receipts to your clients to seek reimbursement on their own), you should still plan on transitioning to ICD-10 - here's why:
*Clients often submit their receipt for out-of-network reimbursement and you may not be aware of it
*By not making this shift when the rest of the entire industry is, you may be questioned on not having an updated/ethical/current standard-of-practice program
*It's a liability risk to you if there is any future legal action involving your and/or your client ("Why aren't you practicing according to current standards?")
ICD-10 codes are required for dates of services after 10/1/15, but claims processed with a date of service prior to 10/1/15 should still be coded in ICD-9, regardless of when they are submitted. For a while, word on the street was that non-HIPAA covered entities such as workman’s compensation would not be required to transition to ICD-10. However, that has been refuted by CMS:
Hire an expert: The simplest way to make this challenge as smooth as possible is to secure an ICD-10 expert to conduct a risk assessment of your practice and get you on track for a successful transition. They can determine how much you will be impacted and create an implementation timeline to ensure you are testing the new codes early enough to catch & fix errors and meet the deadline. Because of the complex interactions between DSM-IV & DSM-5 and ICD-9 & 10, it’s a good idea to hire a consultant well-versed in mental & behavioral health.
Talk to your payers: Start calling your payers now, whether insurance companies or Medicaid/Medicare, and find out when they will be ready to test ICD-10, if they require actual dual coding (other than the standard dual coding for dates of service before & after 10.1.15), and if they offer any ICD-10 tools. Many payers are providing free resources to help ease the transition.
Obtain and organize the codes: If you’re using an EHR, DSM-5 and ICD-10 codes will most likely be provided with plenty of time to test; if not, you’ll need to obtain the new codes yourself from a reputable source. Once the new codes are available, you have to decide how you’re going to train your staff: each department will be affected by ICD-10 diferently, and training should be segmented by role. Obviously, your providers will have the greatest responsibility in changing the way they diagnosis to align with DSM-5 and picking the right codes to align with ICD-10.
It’s each practice’s responsibility to be proactive and ensure compliance. Your EHR can’t talk to your payers - only you know how your organization diagnoses and bills. If you hire a consultant, they may give you a completely different course of action, based on your individual practice; however, here is one example of ICD-10 action items:
*create (or purchase) the necessary conversion tools (such as software or crosswalks)
*train your staff thoroughly on their changing course of action
*test everything: your employees, billing batches, the codes everywhere they are used, etc
*save and set aside: put away as much money as possible in case payments are delayed during the transition (remember the January 2013 CPT debacle!?)
*create updated revenue plans: if it takes your staff 2-3 times as long to process claims, what changes do you need to make to ensure business viability?
See 8 Steps to a Smooth ICD-10 Transition for details.
PIMSY ICD-10 Resource Center
ICD-10 for Behavioral Health blog
How do ICD, DSM, and CPT interact for mental health?
Centers for Medicare and Medicaid Services (CMS) ICD-10 Provider Resources
American College of Physicians ICD-10 Resource Center
ICD-10 Conversion Tool and Resources
AAPC Coding Books
Disclaimer: Ultimately, it is the responsibility of each practice to ensure ICD compliance, including the 10/1/15 ICD-10 transition. PIMSY EMR/SMIS has gathered information from various resources believed to be authorities in their field. However, neither PIMSY EMR/SMIS nor the authors warrant that the information is in every respect accurate and/or complete. PIMSY EMR/SMIS assumes no responsibility for use of the information provided. Neither PIMSY EMR/SMIS nor the authors shall be responsible for, and expressly disclaim liability for, damages of any kind arising out of the use of, reference to, or reliance on, the content of these educational materials. These materials are for informational purposes only. PIMSY EMR/SMIS does not provide medical, legal, financial or other professional advice and readers are encouraged to consult a professional advisor for such advice.