On January 16, 2009, the final rule was published requiring all HIPAA covered entities to adopt the ICD-10 code sets in replacement of the ICD-9 code sets. April 17, 2012 the United States Department of Health and Human Services (HHS) published a proposed rule that would delay the compliance date from October 1, 2013 to October 1, 2014 for the ICD-10 code set implementation. On August 24, 2012 HHS announced a final rule accepting the one-year proposed delay. The compliance date is officially October 1, 2014. Click here for the HHS News Release.
Who is impacted by the change to ICD-10?
All entities using healthcare information that contains a diagnosis and/or inpatient procedure codes will be impacted, including but not limited to all providers, payers, and plans in the United States.
What is ICD-10?
ICD-10 is the 10th revision of the International Classification of Diseases used for morbidity and mortality reporting.
When is the compliance deadline?
October 1, 2014.
Where will ICD-10 impact healthcare?
Conversion to ICD-10 will impact all individuals, systems and procedures that create, record, update, process or report on health care data based on a beneficiariy's medical diagnosis or based on procedures performed in an inpatient setting.
Why change to ICD-10?
ICD-9 is limited in space and in many instances uses obsolete terminology. ICD-10 structure allows for greater specificity, greater expansion and contains updated terminology necessary for current medical practices.
How can you prepare and plan for ICD-10 implementation?
Look through the links below for more information on ICD-10, how to prepare, and information on how Michigan Department of Community Health is working to prepare ourselves and our providers for implementation on October 1, 2014.
MDCH Links
Additional Links for ICD-10 Information
MDCH Implementation Approach
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MDCH completed an Impact Analysis for the ICD-10 implementation which assessed the effects of transitioning from ICD-9 to ICD-10 on our policies, processes, and systems. As a result of this analysis, MDCH was able to identify areas requiring remediation and estimate the amount of time and effort necessary to successfully implement the ICD-10 code sets.
Since there is no direct way to "crosswalk" from ICD-9 to ICD-10, MDCH has taken a "native" approach to our implementation activities. As part of this approach, certified coders have collaborated with clinical staff to identify ICD-10 code equivalents for existing ICD-9 codes in order to facilitate remediation efforts, such as those related to systems.
There will be a cutover from the ICD-9 to ICD-10 code sets based on date of service. All claims submitted with dates of service on or after October 1, 2014 will need to use ICD-10 codes. Due to timely filing rules/standards both code sets will be used simultaneously for some time.
MDCH's policy remediation process involves the identification, promulgation, and finalization of program policies necessary to implement ICD-10. The purpose of this activity is to ensure ICD-10 impacted policies are remediated within compliance timelines.
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General Equivalence Mappings (GEMs)
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Below are the web based tools from different sources regarding the General Equivalency Mappings (GEMs). These provide a foundation for translating codes from ICD-9 to ICD-10. They are NOT a crosswalk and cannot be used without manual review and clinical decision making. A user will also have to consult the ICD-9 and ICD-10 code books to ensure the full range of available codes are considered when making decisions on translation.
It is also recommended you review all three tools as you may see a variance between them, proving that no single source can be used in place of manual review. A user will need an understanding of the GEMs prior to using these tools. Further information can be found on the CMS ICD-10 website listed below.
For ease of use, MDCH is providing a search tool to assist in navigation and for viewing the CMS GEMs.
GEM Viewer
CMS GEMs
2014 ICD-10-PCS and GEMs
2013 ICD-10-CM and GEMs
2013 ICD-10-PCS and GEMs
2012 ICD-10-CM and GEMs
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Blue Cross Blue Shield
BlueGEMs
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AAPC
ICD-10 Code Translator
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Testing
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MDCH will be performing both Internal and External End-to-End (E2E) testing of its systems and procedures impacted by migration to ICD-10, in order to ensure those systems meet the State's information requirements without unexpected financial or operational impact on the State, its providers or trading partners.
Our Internal E2E Testing will include a broad range of testing activities including developer testing, unit testing, integrated system testing and user acceptance testing. Internal testing timelines vary from system to system, but in general we plan to complete our Internal E2E Testing activities for all impacted systems by December 31, 2013.
External E2E Testing activities will be conducted with those business partners, trading partners and providers who communicate with MDCH using ICD-coded transactions. For our Business Partners (who perform services under contract to MDCH), we will initially focus on monitoring their system remediation activities. This will be performed to ensure their systems and procedures will properly support operations under ICD-10. This monitoring activity is currently in process and will continue through October 1, 2014, the ICD-10 compliance date.
We will provide multiple opportunities for our providers and trading partners to conduct testing with MDCH. These major testing phases include:
- Scenario-based Testing - MDCH is currently in the process of developing spreadsheets that describe common clinical situations for which our providers currently provide services to Medicaid beneficiaries. These scenarios each describe both diagnostic data regarding a beneficiary as well as procedures performed, for a hypothetical claim situation. We will encourage our providers to review whese scenarios, code the beneficiary diagnosis and/or procedures performed using ICD-10 codes, and forward those spreadsheets containing ICD-10 codes to MDCH for review and feedback.
This Scenario-based Testing will allow our providers to ensure that their clinical systems and procedures provide for adequate data collection to support accurate ICD-10 coding, for high-volume, high-dollar or other typical claims scenarios currently reported to MDCH. This Scenario-based Testing does not require our providers to have fully remediated systems able to generate test ICD-10 claims. The provider must only be capable of transaction coding using ICD-10. Similarly, MDCH will not attempt to adjudicate or process these coded scenarios or calculate payment amounts. We plan to begin posting claims scenarios on the MDCH website by July 2013 through the compliance date, with the heaviest testing activity expected in the latter half of 2013.
- Volume Comparative Testing - MDCH is hoping to conduct Volume Comparative Testing with a select, small group of Trading Partners willing and able to send us a high volume of electronic transactions dual coded in both the ICD-9 and ICD-10 code sets. We will seek Trading Partners who can supply at least a week's worth of transactions for comparative processing to assess adjudication results under each coding approach. This testing is not planned to commence until April 2014 and will require extensive coordination.
- Business-to-Business Testing - Trading Partners and Providers will be encouraged to test claim adjudication and encounter processing functions using the CHAMPS B2B Test environment (hosting a test version of the ICD-10 compliant version of CHAMPS). We will provide claim processing adjudication reporting, encounter processing reports and 835 remittance advice transactions to our Trading Partners, for their review and testing functions. This will enable Trading Partners to determine whether their remediated systems can produce and process those transactions.
Trading Partners will be able to submit test files to the B2B Test System through:
1) The State's Data Exchange Gateway (DEG)
2) Direct upload of EDI transactions using CHAMPS web-batch upload functionality, or
3) Web-enabled Direct Data Entry (DDE) submission.
The B2B Test System will validate that ICD-10 coded transactions process and generate appropriate CHAMPS response transactions, which the Trading Partner may use to confirm that response files process in their internal systems. Trading Partners will be requested to test using the native ICD-10 Diagnosis and Procedure codes they plan to submit following ICD-10 implementation.
We plan to commence B2B Testing activities with a limited number of selected providers in October 2013, and offer all providers and trading partners an opportunity to perform B2B Testing in January 2014. We will publish B2B Testing instructions on the MDCH website.
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Other MDCH links and related sources
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ASC X2 TR3s and MDCH Companion Guides
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HIPAA 5010 Transaction Testing
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Electronic Submitter Manual
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