Implementation of ICD-10 coding for MMSEA Section 111 Reporting

Earlier this week, we posted a blog notifying subscribers that CMS had issued an alert regarding implementation of ICD-10 coding as it relates to MMSEA Section 111 reporting.

This follow up blog provides a more in depth summary of the recent CMS alert.

Transition from ICD-9-CM to ICD-10-CM Diagnosis Codes

The CMS alert provides a timeline surrounding significant events and additional information to be released by CMS regarding ICD-10 conversion. The alert states that both an additional alert on excluded ICD-10-CM codes as well as an updated NGHP User Guide will be released “at a later date.” PMSI anticipates that both the alert and updated NGHP User Guide will likely be issued this summer, prior to testing of ICD-10-CM codes this October.

On October 1, 2013, CMS will begin testing by RREs and allow test claim input files with ICD-10-CM codes to be submitted by RREs. One year later, on October 1, 2014, CMS encourages, but is not requiring RREs to submit claim input files with ICD-10-CM codes.

Starting on April 1, 2015, CMS will require ICD-10-CM codes on production files where the DOI is on or after April 1, 2015.   

Changes to Claim Input File Detail Record Layout and Submission Requirements

The alert provides specific information regarding changes to file specification used to report claims to CMS. To accommodate ICD-10-CM coding, nineteen 2-byte fields already included in the file specification as “reserved for future use”, and it will be incorporated into the existing 5-byte ICD-9-CM fields which brings each field to 7-bytes total.

In addition, a new ICD Indicator field will be added in another field that was reserved for future use. The ICD Indicator will be a 1-byte field that will have valid entries of a space, “0” for ICD-10-CM or a “9” for ICD-9-CM codes. A space will also indicate all ICD-9-CM codes. Claims will need to be submitted with all ICD-9-CM codes or all ICD-10-CM codes. No mixing of code versions will be allowed on a single claim.

As changes to the ICD fields and the new indicator were prepared for previously with the reserved fields, the remaining fields in the specification will align with their current location in the detail record.

During the interim period of October 1, 2014 to April 1, 2015, compliance flags will be returned on all records submitted to CMS where ICD-9-CM codes were submitted but the CMS DOI is on or after October 1, 2014. The compliance flag is intended as a warning indicator that the final production date of April 1, 2015 is approaching. 

PMSI is currently evaluating internal processes and controls as they relate to contents of this alert. As we receive further instructions for integrating the new ICD-10 requirements into our shared processes, we will share the further detail and clarification.  

The full CMS alert can be viewed by clicking here.

Leave a Reply