In my last post, I discussed Transmittal 1122, which announced the addition of codes to the translated NCDs CMS intends to release. Specifically, CMS says, “the purpose of this change request (CR) is to both create and update national coverage determination (NCD) hard-coded shared system edits that contain ICD-9 diagnosis codes with comparable ICD-10 diagnosis codes plus all the associated coding infrastructure such as procedure codes, HCPCS/CPT codes, denial messages, frequency edit. POS/TOB/provider specialties, etc.” Today, I want to explore what this means to physicians and other health care providers.
With regard to compliance, I’ve heard many visitors to this blog are searching for answers to their questions about “medical necessity.” CMS intends to make your life much easier by providing specific medical necessity requirements in their translated NCDs. They are also attempting to “harmonize” the policies. By that I mean, if Policy A says “red,” the goal is to say “red” in other instances related to the policy. This will help reduce confusion and support increased coding accuracy and medical necessity compliance.
The expanded options found in ICD-10 will make it easier for providers to be compliant because they will be offered a greater range of possibilities that represent their patient’s condition. For instance, NCD 270.3 Blood Derived Products for Chronic Non-Healing Wounds will go from zero ICD-9 diagnosis codes to over 300 ICD-10 choices. Yes, I know it seems overwhelming, but remember when you were learning to drive? That was overwhelming too, but now you are a great driver. The range of options will also make it easier to choose the right diagnosis for each case. This is more good news for providers; since it is likely you perform the same services on a repetitive basis, the newly translated policies will provide the ICD-10 codes you need.
Another plus: If you do not check medical necessity because the current policies are simply too vague or confusing and you found it difficult to implement a process, get ready, because now is the time to start. CMS gives clear guidance on the process, including providing ABNs (Advanced Beneficiary Notices) when necessary. This makes a lot of sense; compliance reduces your risk on prepayment RAC audits claim denials. So enjoy the gift of the newly translated and coded polices – as my daughter would say, it’s like chocolate without the calories for those of us in the compliance business.
Barbara Aubry is a Regulatory Analyst with 3M Health Information Systems.