ICD-10 Preparation: Not Planning to Transition to ICD-10 as of Oct. 1, 2013? You Might Be Liable to Face Millions in Fines, CMS Reps Say

Why This Topic Matters

Organizations affected by CMS billing rules needed to know how the ICD-10 transition could affect claim acceptance, compliance exposure, and payer-specific handling of dates of service. The article summarizes the operational and regulatory topics most relevant to planning for implementation.

Article Sections

1. Introduction

   Sets up the CMS guidance discussed in the article and frames the transition issues affecting Medicare claims and related billing workflows.

2. Question 1: How will CMS handle claims that span from before Oct. 1, 2013 through dates after Oct. 1, 2013? Should the practitioner use ICD-9 or ICD-10 codes for these claims?

   Addresses CMS comments on claims that cross the implementation date and the broader question of how different claim types may be handled.

3. Question 2: Will workers' compensation insurers still use ICD-9, even after the rest of the industry transitions to ICD-10 after Oct. 1, 2013?

   Summarizes CMS discussion of workers' compensation and Medicaid transition timing, including how payer adoption may differ across programs.

4. Question 3: What are the penalties for entities that are covered under HIPAA who choose not to use ICD-10 codes as of Oct. 1, 2013?

   Covers CMS remarks on claim denial and HIPAA-related compliance exposure tied to the transition date.

5. Question 4: The Medicare local coverage decisions (LCDs) currently list the payable ICD-9 codes that correspond to all Medicare-payable procedures. Will contractors issue updated LCDs to the public prior to the Oct. 1, 2013 implementation date that show the payable ICD-10 codes for the procedures?

   Discusses CMS comments about updating Medicare coverage policies and whether translated materials would be available before implementation.

6. Question 5: When will CMS finalize the ICD-10 code set?

   Explains CMS remarks about the timing of ICD-10 code set updates and the version expected to be used for implementation.