Note: My post below is my actual, unedited response to the post Dr. Girgis made on Health Care IT News website. Prior to posting it, I shared a copy with Dr. Linda Girgis. Not surprisingly, the good doctor responded in very complete and professional manner. Her clarifications make a lot of sense and I can’t say I disagree with any of her follow-on points. Dr. Girgis’ entire, unedited response to me can be found here. (I have her permission to post it)
This post is a response to the post titled “6 glaring and disruptive ICD-10 glitches” written by Dr. Linda Girgis and posted on the Health Care IT News website.
The title of the post immediately caught my eye. After reading it through – twice – I didn't appreciate that all six 6 glitches could be attributed to ICD-10 - although a few of them could be attributed to ICD-10 AND ‘glaring’ and ‘disruptive’ as the title of the post states. To be sure, I have “known” Dr. Linda Girgis on Twitter for a while now and I respect that she's a straight shooting physician who often shares different perspectives on the use of technology in healthcare. That’s a rare breed of physician for sure.
I have the following questions and comments on the glitches claimed to have been caused by the cutover to ICD-10:
1. So much for the CMS grace period.
I’m not sure what the issue is here. The grace period was granted by CMS and applies to Medicare and Medicaid claims only. CMS communicated this a while ago and it shouldn't be a surprise. Moreover, all non-CMS health plans didn't have to offer the same grace period.
In regards to ICD-10 taking more time to code, this should also not be a surprise. How much of that extra hour may be due to the newness and perhaps learning curve?
It sounds like Dr. Girgis’ clearinghouse screwed up or is intentionally ignoring CMS. I’d be curious which clearing house this is. If they're violating CMS regulations, that can’t be good – for them. Either way, this is a glaring and disruptive issue.
Truly urgent referrals generally have specific turnaround times of 24 – 48 hours. I’m curious as to how the payer would respond in regards to the eventual adjudication of the claim if they knew their referral service was down, that the referral was truly urgent and the ICD-9 equivalent for the service would typically be considered urgent? Would they actually deny if for “No valid referral?” And I realize there might be a slim chance there was not an equivalent ICD-9 code. I suppose this might be considered glaring and disruptive.
4. Eligibility Checks
This one isn’t clear to me. What did the “Eligibility verification” services have to do with ICD-10? Was this for benefit determination on a specific condition defined by a diagnosis code? If so, then yes: glaring and disruptive.
The statement that “Any patients I saw on the first 2 days of October who we were unable to verify their insurance was treated for free and there's nothing I can do about it” just doesn't seem reasonable to me. This should only apply if the patient was truly not eligible for services. Nor does this comment about free treatment jibe with the previous statement of “we may or may not be paid.” I think it’s unfair to blame ICD-10 and to just give up on billing the services to the payer. How does Dr. Girgis know the claims won’t be paid?
5. Wait times
This is unfortunate but not the "fault of ICD-10." But surely the biller was not just sitting there doing nothing while waiting on the phone. If so, why? Might want to provide a little education and training as to leveraging ‘wait time?’ Again, it’d be good to know the health plan that had 3 hour wait times. Maybe a little public shaming is in order? :)
It would be helpful to know what kinds of questions were asked of the health plan personnel and who the health plan was. This impresses me as another instance where the health plan should make good on any misdirection their staff provided. In this case, I wouldn't blame ICD-10 per se but rather poor staffing and training of health plan staff.
So to me, not all of these are directly attributable to ICD-10. And I don’t think it’s fair to categorically state that the affected claims won’t be paid. For sure the claims won’t be paid if they're not submitted but why not submit them along with more details on the information presented in the post? I don’t know the specific health plans involved and maybe I’m being too optimistic but I would think Dr. Girgis has valid reasons why her claims should be paid.