Are Clinical Labs and MACs Ready to Implement ICD-10?

ACLA expresses concern that Medicare contractors may use ICD-10 as a way to limit payment under some local coverage determinations

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ARE CLINICAL LABORATORIES and pathology groups prepared for ICD-10? Or, perhaps a better question to ask is this: Are Medicare administrative contractors prepared to switch to ICD-10 on October 1?

A recent survey of clinical laboratories and pathology groups by McKesson Corporation showed that 18% of respondents were unprepared for the transition to the more complex coding set for ICD-10. Further, 31% were only partly ready for the transition. The remainder were prepared, McKesson data show.

The total of 49% of labs and pathology groups that were not quite fully ready is worrisome because unprepared provider organizations may not get paid until they make the transition to ICD-10. Experts recommend that providers set aside three to six months of cash as a reserve in case payments stop because the lab, health plan, or MAC is unprepared to process claims using ICD-10.

While MACs may be ready to process claims using ICD-10, the American Clinical Laboratory Association wrote a letter to the federal Centers for Medicare & Medicaid Services last month to point out that many of the MACs’ local coverage determinations were incompatible with ICD-10.

After reviewing several LCDs, JoAnne Glisson, the ACLA’s Senior Vice President, wrote to officials at CMS saying, “We have found that several of the future LCDs do not include the full range of ICD-10 codes that map to the ICD-9 codes in the current policies. This may result in non-coverage for some currently-covered laboratory services, without the benefit of comment and notice periods, and it also may result in laboratories having to code improperly in some cases to be paid for their services.”

Will MACs Limit Coverage?

There could be many reasons that some MACs did not use the ICD-10 mapping tools, she added. “In any event, we are concerned about the operational and claims processing effects of contractors’ coding decisions,” she wrote.

ACLA is concerned because the MACs may use the transition to ICD-10 to limit coverage for clinical laboratory services without allowing labs to comment, wrote Glisson. “We believe that all MACs should be required to use a notice-and-comment process if they intend to limit the indications for which certain tests are considered medically necessary,” her letter said. ACLA requested a meeting with federal officials to discuss these concerns.

In addition to setting aside at least three months of cash reserves, experts recommend that providers contact all vendors and business partners to ensure that they are ready to comply with the ICD-10 coding requirements. These vendors and partners include health plans, federal and state payers, clearinghouses, and any labs that serve as vendors or business partners.

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