ICD-10-CM

 

Clinical laboratories are among the HIPAA covered entities that must transition from the current ICD-9-CM diagnosis code set to the new ICD-10-CM diagnosis code set in standard electronic administrative transactions for services provided on and after October 1, 2013.  While clinical laboratories share many of the ICD-10-CM implementation issues faced by other health care providers, some issues, or their degree of impact, are unique to indirect providers such as clinical laboratories, and those differences must be taken into account to ensure a successful transition for all.  Resolution of these issues will require cooperation from multiple stakeholders in industry and government. 

Clinical laboratories are indirect providers, and the challenges and opportunities presented by ICD-10-CM can only be understood in that context.  Since labs typically don’t see the patient, they must rely on the ordering provider to provide the diagnosis coding information that the lab must submit to third party payers for reimbursement.

Given the indirect provider status of clinical laboratories, the importance of educating and training ordering providers and their office staffs cannot be overstated.  Appropriate education and training will be critical to the success of the transition to ICD-10-CM, and both CMS and labs have key roles to play. 

 

Sequencing and coordination of ICD-10-CM implementation efforts must follow a rational plan to avoid systemic disruptions.  For the transition to ICD-10-CM, not only will the industry need a rational test sequencing plan, but the massive scope of ICD-10-CM implementation must be prioritized against other HIPAA implementation efforts (e.g., claim attachments) and efforts to accelerate health information technology adoption and health information exchange (e.g., “meaningful use” of electronic health records). 

Standardization of crosswalks and crosswalk implementation is important not just for payers, but for clinical laboratories and other providers as well.  Just as payers have expressed interest in “backward” mappings from ICD-10-CM to ICD-9-CM for internal processing purposes, indirect providers such as clinical laboratories need a forward mapping from ICD-9-CM to ICD-10-CM for claim submission purposes for those instances in which an ICD-9-CM code is received from an ordering provider when an ICD-10-CM code must be reported to the payer.  Both backward and forward crosswalks should be standardized across the industry to avoid inconsistent results.

Early adoption, late adoption and non-adoption of ICD-10-CM in non-standard transactions (e.g., test orders) could threaten the ability of clinical laboratories to process compliant claims.  Conforming changes should be made to close the regulatory gap between the requirement that clinical laboratories submit diagnosis codes in standard transactions and the lack of a requirement to submit diagnosis codes to clinical laboratories in non-standard transactions such as test orders.   

 

ACLA supports an appropriate “freeze” on updates of ICD-9-CM and ICD-10-CM during the transition.

 

Helpful Links:

General ICD-10 Information

ICD-10-CM Coding System, Mappings and Guidelines

AMA ICD-10 Website

AHIMA Website