Sandy's Corner

ICD-10-CM Diagnosis Code F05, O Brother, Where Art Thou???

I am never really too sure how to take any action that occurs on April 1 and when the Federal Government takes action on said day I am doubly suspicious; therefore, you will understand my reticence of the news that on April first President Obama signed H.R.4302 extending (among many other things) the federal ICD-10 implementation until at least October of 2015.

Just when we needed it the most, the ability to use ICD-10-CM Diagnosis Code F05 (Delirium, Not Induced by Alcohol and Other Psychoactive Substances) with the federal government has been taken from our grasp. Some key symptoms of F05 are … clouding of consciousness, i.e. reduced clarity of awareness of the environment, with reduced ability to focus, sustain, or shift attention (potentially including): impairment of immediate recall and recent memory; disorientation in time; rapid, unpredictable shifts from hypo-activity to hyper-activity; enhanced startle reaction; and, disturbing dreams and nightmares which may continue as hallucinations illusions after awakening. ICD-10-CM Diagnosis Code F05, O Brother, where art thou whence we need thee most!?

As we will not formally have the ICD-10 code set at a federal level until at least October 1 of 2015, we will have to make do with what we have –ICD-9. So make do we will. Unfortunately, as we do not fully know what this delay will mean for all 50 states, we will all have to continue to monitor the determinations by the states until all the dust fully settles. The early belief is that no one state will make the singular leap to impose the use of the ICD-10 code set on its system of providers, payers and vendors, but stranger things have happened. 

While no regulatory entity may ultimately legislate the use of ICD-10 codes, the question still remains, “will any provider, payer, or vendor be precluded from using or requesting the use of ICD-10 codes either formally or experimentally prior to October of 2015 as a significant amount of time, training, and money have been spent to prepare for their use and a skill learned but not used will dwindle and/or vanish?” Further complicating this question, is the fact that also on April 1, the use of the CMS 1500 claim form version 02/12 became mandatory. Per MLN Matters® Number MM8509:

The revised form has a number of changes. Those most notable for Medicare are new indicators to differentiate between ICD-9 and ICD-10 codes on a claim, and qualifiers to identify whether certain providers are being identified as having performed an ordering, referring, or supervising role in the furnishing of the service. In addition, the revised form uses letters, instead of numbers, as diagnosis code pointers, and expands the number of possible diagnosis codes on a claim to 12. … Form Version 02/12 will replace the current CMS 1500 claim form, 08/05, effective with claims received on and after April 1, 2014:

  • Medicare will begin accepting claims on the revised form, 02/12, on January 6, 2014;
  • Medicare will continue to accept claims on the old form, 08/05, through March 31, 2014;
  • On April 1, 2014, Medicare will accept paper claims on only the revised CMS 1500 claim form, 02/12; and
  • On and after April 1, 2014, Medicare will no longer accept claims on the old CMS 1500 claim form, 08/05.

Sure, workers’ compensation is exempt from the HIPAA requirements and can really do its own “thing” if it wants to do so, but when was the last time in an open capital market that you saw roughly two percent of the market tell the other ninety-eight percent what to do? (Yeah, me neither.) So what all this means is that the policyholder community should continue to make sure that their carrier and their carrier’s vendors are aware of all the actions in each state, that they are compliant with the new CMS 1500 02/12, and are or will be fully prepared for the ICD-9 to -10 conversion when called upon to do so. Medata is compliant with the CMS 1500 02/12 and will be prepared for the use of ICD-10 codes this October if (on the remote chance) we are required to do so by regulators and/or customers. If not required to do so in 2014, we will be more than ready to go if and when the bell rings in October of 2015. In the meantime, it does not hurt to do a little due diligence with your business partner(s) in order to make sure that they too will be ready when called upon so that you can avoid your own diagnosis of ICD-10-CM F05.