AS I SEE IT Coders are in the best position for


determining whether a physician’s cur- rent operative documentation can be reported to the highest specificity in ICD-10. The ASC coder should be dual coding, at a minimum for some cases, from not only a “hands-on experi- ence” perspective but also from a doc- umentation analysis perspective. It is one thing for a physician to go to a conference and hear the documenta- tion requirements, but physicians who feel that they already meet the neces- sary requirements won’t feel an urgent need to change. Comparisons of ICD- 10 diagnosis coding with current real- time documentation per physician can provide physicians with actual exam- ples of the good, the bad and the ugly. Both ASCs and physicians should


work together to ensure that appro- priate education is provided. There are many resources available, and many are tailored to the best method of learning for the individual. Many organizations such as the Ameri- can Academy of Professional Coders (AAPC) offer training for both cod- ers and physicians with a physician to physician training for physicians. Many state medical societies are also offering training.


II. Budgets ASCs might face disruptions in their payments following the implementa- tion of ICD-10, even if they are on tar- get to operate using ICD-10 codes at that time. The storm preparation say- ing “Prepare for the worst and expect the best” comes to mind. A few points to remember:


ASCs will need to be able to keep their doors open or, more specifically, to pay rent and staff salaries, even if the transition does not flow as smoothly as testing may indicate. Experts advise having up to several months’ cash reserves or access to cash through a loan or line of credit.


10 ASC FOCUS JUNE/JULY 2014 ASCs should communicate with


banks regarding lines of credit before funds are needed. Banks are more willing to consider a loan or line of credit while an ASC is in good stand- ing than when it is 3-6 months past due on its bills. The amount of cash reserves that an ASC will need will depend on the size and shape of the facility or practice


III. Contingency Planning


The transition from the Medicare claims format HIPAA 4010 to 5010 in January 2012 provides a valuable lesson. Some carrier challenges involving Medicare payment delays did not arise until three or four weeks after the new forms were in use. Some of the claims were not getting formatted even though they were passing through all of the edits that had been programmed for the update. Although vendor soft- ware systems, clearinghouses and pay- ers will do a great deal of testing and preparation, the true impact of ICD-10 will not be felt until it goes live. Productivity. Expect a decrease in productivity dependent on the experience of your ASC’s coder, the quality of the clinical documenta- tion your billers and coders receive and your ASC’s case mix/complexity.


Let’s learn from Canada’s implemen- tation when the average same day surgery case load was reduced from approximately 10.86 to 3.82 day sur- gery accounts during the initial phase. In a worst case scenario, your ASC’s coding might decrease initially from an average of 8–11 multi-specialty charts to 3–4 charts per hour. Any delay in billing will ultimately spill over into the timeliness of the reim- bursements that your ASC can expect. Outsourcing. Consider outsourcing coding to address any backlogs and allow on-staff coders more time to learn and practice ICD-10. Restructuring. When feasible, con- sider assigning staff who are already experienced with ICD-9 to ICD-9 claims and staff who are more well-versed in ICD-10 claims to ICD-10 claims until the “old” claims are resolved. Communicating with Payers. ASCs


and providers must check with payers to determine if they have a contingency plan in the event of a disruption and what they intend to do for providers to ensure that they are not left with a significant cash flow crisis. A problem with even one payer can prove disastrous if that payer is responsible for even 30 percent of a facility’s volume and revenue. Reviewing Contracts. ASCs should check their contracts for timely reim- bursement penalties that their payers can assess should a delay in payment occur. In addition, ASCs should review their software vendor contracts to verify support timeframes and response times. ASCs need to determine the recourses open to them if the agreed-upon time- frames and response times are not followed, including whether credit is available for these support services if they are not provided.


Cristina Bentin is the president of Cod- ing Compliance Management LLC in Ba- ton Rouge, Louisiana. Write her at cris- tina@ccmpro.com.


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38