On ICD-10 Release Date, CMS Says Four States Are Exempt

On October 1, 2015, the ICD-10 implementation date, four state Medicaid programs won’t be transitioning to ICD-10 like the other 46. Instead, they have received CMS approval to take incoming claims coded in the new ICD-10 system, convert them into ICD-9 codes, and use the older system to calculate payments to healthcare providers.

All HIPAA-covered entities, including hospitals, office-based physicians, claims clearinghouses and health plans must comply with the federal mandate for full ICD-10 conversion on Oct. 1. But the CMS has signed off on a “crosswalk” approach to translate ICD-10 codes into ICD-9 codes and keep using the older codes as a workaround for Medicaid fee-for-service programs in California, Louisiana, Maryland and Montana.

These four states “are the only [ones] that have programmed the backwards crosswalk into their claims processing systems for their fee-for-service providers,” Jibril Boykin, press officer at the Centers for Medicare and Medicaid Services (CMS), said in an email. Every other state and provider, however, is still federally mandated to convert to the code set on October 1, 2015.

“We have worked closely with each state to understand how they will mitigate any issues that may arise and minimize impact on the accuracy and timeliness of provider payments,” said Boykin. It is “not a long-term approach,” and the “crosswalk” approach “varies on a state-by-state basis.”

Explaining the Crosswalk Approach

As for the crosswalk approach, the four states “are going to take in [an ICD-10] code, they are going to crosswalk it to [an ICD-9] code, [and] adjudicate the claim,” said Robert Tennant, director of health information technology policy at the Medical Group Management Association in Englewood, Colorado. “So, that means they basically haven’t converted to ICD-10.” Tennant also stated that he expects there will be more states that will use this crosswalk approach in the future.

What Are the Pitfalls?

Health IT consultant Stanley Nachimson said crosswalking from ICD-10 to ICD-9 codes has its pitfalls. “It’s certainly not the preferable way,” he said. “There are some ICD-10 codes that do not crosswalk back to ICD-9 codes.” In addition, the crosswalk approach also allows for compromised data quality from “convoluted codes” , as well loss of revenue from delayed or rejected claims due to cross-coding issues.

“I don’t think [crosswalking is] a good solution…in my opinion,” stated Nachimson. “It’s taking the easy way out and not getting to the right answers. They should have gotten their machines ready. They could have talked with some other states and seen how they’ve done it.”

The four state Medicaid programs may not be the only payers using the crosswalk technique, said Holley Louie, president-elect of the Healthcare Billing and Management Association. “We’ve heard from some of the smaller commercial plans that they’re going to do the same thing.”

Why Did States Need a Crosswalk Waiver?

It has been reported that representatives from Medicaid programs in Louisiana and Montana could not be reached for a comment by the deadline, but that a Maryland Medicaid spokesman said his state took this approach because its “system architecture does not allow for ICD-10 native compliance,” adding that the state will use the crosswalk until it has migrated to a new system.

In California, Medi-Cal’s crosswalk wasn’t a quick fix at the last minute. According to California Department of Health Care Services spokesman Adam Weintraub, in March 2010 California approved a six-year, $1.6 billion contract with Xerox Health Systems to upgrade the software for its Medicaid management information system. A proposal to upgrade to ICD-10 and use a coding crosswalk were in Xerox’s response to California’s request for proposals bid from the beginning.

CMS had signed off on California’s use of a crosswalk when it approved funding for the upgrade project, Weintraub said. Xerox began work on the ICD-10 enhancement in November 2010, he said. It was implemented in September 2014 after nine months of extensive system testing, including external testing with Medi-Cal providers, Weintraub said. It’s continuing those tests now “to verify equivalency of claims adjudication for ICD-9 coded claims to ICD-10 coded claims for the same medical scenario.

In an FAQ page on the Medi-Cal website, the state agency said its crosswalk “will only be used temporarily.”

Doubting The System

One thing we do know is that these crosswalk ‘wavers’ have confirmed something we’ve all been thinking – that perhaps the government isn’t completely ready for the transition. “CMS has stated many times that the [state Medicaid programs] were ready, and, of course, we’re finding out that [they are not],” Tennant said. Allowing the four states to use this crosswalk approach will cause the already skeptical healthcare community to ask now more than ever before: why do we need to convert to ICD-10?


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