On October 1, 2014 your systems and procedures will have a choice to make: Claims with dates of service (professional) or discharge dates (institutional) PRIOR TO 10/1/14 must be processed based on ICD-9 codes. Claims with dates of service (professional) or discharge dates (institutional) AFTER 10/1/14 must be processed based on ICD-10 codes. This capability is generally referred to in the industry as “dual use” capabilities.
But Will Dual Use Capabilities Be Sufficient?
Based on what I’ve read and understand, most payers will establish a policy of rejecting claims that contain the wrong ICD code relative to the currently defined 10/1/14 compliance date; either the claim is processed or rejected. But what happens if CMS waffles again and allows a “non-enforcement period” subsequent to 10/1/14? Perhaps allowing providers to submit claims containing ICD-9 or ICD-10 codes without regard to date of service (professional) or discharge dates (institutional) - just like CMS did earlier this year with HIPAA 5010 transactions.Some Questions for Now - Rather Than Later
Will your systems and processes be flexible enough to accommodate the non-enforcement period? What design approaches, planning and testing considerations can you make now to accommodate potential relaxation of the ICD-10 compliance date? If you are dependent on vendor solutions, are those solutions capable of both dual use and flexible use?