One often overlooked but potentially critical step in the preparation for the October 2014 transition from ICD-9 to ICD-10 is updating agreements between providers and payers. Although the change is ultimately expected to be valuable due to the increased specificity and granularity of diagnosis coding, the potential for unintended financial consequences should not be understated. Most providers are well under way with their operational transition plans, but many have not considered amending their payer agreements to mitigate the potential impact of problems that arise.
Specific risks to address include:
- Loss of revenue due to coding changes
- Delays in claim submission or adjudication due to operational issues
- Lack of a defined contingency plan
- Operational issues, such as claims being incorrectly denied, that require resolutions
To mitigate these risks, we suggest that providers consider the following points when negotiating amendments to their payer agreements.
Revenue neutrality. How will providers confirm revenue neutrality? We suggest an approach that consists of both prospective and retroactive validation, comparing representative claim samples using both ICD-9 and ICD-10 diagnosis coding. If a sample indicates a financial variance, the applicable inpatient and outpatient prospective payment base rates, per diems, and other diagnosis-dependent payment methodologies should be adjusted before the ICD-10 transition occurs.
A retrospective review should be conducted to confirm that revenue neutrality occurred. If revenue changed due to coding methodologies alone, a methodology will be needed to make each party whole.
Testing. What is the schedule for testing? Which criteria will be used to determine its success? Although testing should already be in progress, we suggest that providers determine the key milestones and factors that will be used to indicate that they are ready to “go live” or that the contingency plan will need to be initiated.
Operations. What type of protection is needed against problems with claim submission? How will the payer compensate the providers for delays in claim payments? Will the payer assist the provider with improving coding? One consideration for protection against claim submission is the allowance for an extension of timely filing deadlines during the transition period. If the payer is unable to adjudicate claims timely, there should be provisions for interim payments and subsequent reconciliation.
Rather than automatically denying claims that are coded incorrectly, providers should require a transitional period during which they can work with insurers to improve coding skills and capabilities. This period should include a long-term process for monitoring performance and improving the quality of coding.
Contingency planning. How should providers and payers plan for the possibility that claim payment operations could fail due to the change in coding? Coding issues, like other transition considerations, should be addressed in advance rather than waiting for a potential crisis. Providers should consider requiring interim payments subject to retroactive reconciliation if operations appear to be affected or revenue neutrality is in jeopardy.
Because provider reimbursement methodologies are highly dependent upon proper diagnosis coding, there is a very real possibility that the change from ICD-9 to ICD-10 could adversely affect revenue cycles. Certainly, providers hope to avoid this negative prospect through careful advance transition planning, including efforts to ensure that potential impacts can be mitigated. With only 10 months to go before the ICD-10 implementation date, it is critical that providers review their payer contracts and address possible transition-related issues with the payers.
Charles Brown is a senior manager, ECG Management Consultants, Inc., Arlington, Va., and a member of HFMA’s Colorado Chapter.
Publication Date: Thursday, January 09, 2014