The ICD-10 Grace Period: What It Is and Is Not

On July 6, the American Medical Association and the Centers for Medicare & Medicaid Services (CMS) jointly announced elements of a "grace period" for the Oct. 1, 2015, implementation of the ICD-10 medical billing and coding system. This is good news but not the deliverance physicians were hoping for. 

Here is what the grace period is and is not:

What this is not: It is not a delay of ICD-10. Starting Oct. 1, 2015, you still must use ICD-10 codes on your claim forms and an ICD-10 code from the right family of codes. Medicare — and other payers — will not pay you if you don't use ICD-10 codes as of Oct. 1. This means you must continue your ICD-10 preparation apace. You and your coding staff still need to learn how to use the codes, and your practice still must make system changes to accommodate the codes and test with Novitas Solutions to make sure your claims will process smoothly.

What it is: "a giant burden slightly eased," in the words of TMA President Tom Garcia, MD. The grace period gives practices and Medicare payers time to adjust to the new system and work out problems without threat of crippling payment delays or penalties for physicians.

CMS says grace period entails the following:

  • For one year starting Oct. 1, 2015, Medicare will not deny claims denied solely on the specificity of the ICD-10 diagnosis codes as long as the physician submitted an ICD-10 code from an appropriate family of codes. In addition, Medicare will not audit claims based on the specificity of the diagnosis codes as long as they are from the appropriate family of codes. 
  • To avoid potential problems with midyear coding changes in CMS quality programs (Physician Quality Reporting System, value-based payment modifier, and meaningful use) for the 2015 reporting year, physicians using the appropriate family of diagnosis codes will not be penalized if CMS experiences difficulties in accurately calculating quality scores. CMS will continue to monitor implementation and adjust the duration if needed.
  • CMS will establish an ICD-10 ombudsman to help receive and triage physician and provider problems that need resolution during the transition.
  • CMS will authorize advance payments if Medicare contractors such as Novitas Solutions are unable to process claims within established time limits because of problems with ICD-10 implementation.

See CMS' FAQs for more information. And, dial in to CMS'Aug.27 MLN Connects National Provider Call: Countdown to ICD-10 (free, but you need to register to reserve a spot) for guidance, tips, updates. The call is scheduled for 1:30-3 pm CT.

Remember, the sooner you learn to code claims and document services to the full level of specificity, the sooner you can get paid most accurately for your services.

TMA, meanwhile, is ramping up our ICD-10 educational materials for physicians and your staff:

  • Registration is open for TMA's live seminars: ICD-10 Essentials: Two seminars in one day. In Essentials in ICD-10 Coding and Auditing, staff can perfect their new coding and auditing skills with hands-on exercises using ICD-10. In Essentials in ICD-10 Documentation, physicians can find out how to change their documentation to support increased code specificity and and get paid most accurately for their services. It runs Aug. 4 through Sept. 16 in cities around the state.
  • Take specialty-specific, physician-developed three-hour online courses. Choose from 21 medical specialties to learn physician documentation tailored to your specialty. Each self-paced course shows you critical documentation elements you'll need to maintain payment under ICD-10 and features the top clinical conditions for each specialty with emphasis on their associated documentation and coding requirements. Complete this online documentation training now. Use coupon code 10DOCTMA to save $100 on the registration.
  • Register for on-demand recordings of ICD-10 planning and implementation courses.
  • Visit TMA's ICD-10 Resource Center for tools and information.

 Published July 10, 2015

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Last Updated On

December 12, 2016