I bet you are wondering what April 10, 2014 is! If you guessed that April 10, 2014 is my birthday, you are not correct. Sorry, my zodiac sign is Leo, not Aries but thank you for thinking of me!!
Actually, CMS has announced that April 10, 2014 is the “no-later-than” date which Medicare contractors must publish on the Medicare coverage database (MCD) their local coverage determinations (LCDs) and related articles for ICD-10. Why do you think CMS decided on April 10th? When looking at the characteristics of the Aries sign, maybe there is a subliminal message contained within? Well, I doubt that a subliminal message was CMS’ intention when selecting April 10th as the “no-later-than” date.
CMS published MLN MM8348 on September 6th stating that the April 10th deadline will give providers plenty of time to make system-specific billing changes. Please make sure your business office folks are aware of this and begin discussions with software vendors.
In addition, all LCDs and articles will receive a new identification number. For example, LCD 1234 might become LCD 4567. CMS states that even though there will be new LCD identification numbers, they do not consider these new policies. CMS considers this update to be a coding revision which doesn’t change the coverage and/or non-coverage information within each LCD. The MM8348 can be found by clicking on this link http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8348.pdf
If a Medicare Administrative Contractor (MAC) translates only the ICD-9 codes to the appropriate ICD-10 code, the policy doesn’t need to be examined through its Carrier Advisory Committee or be sent through the public comment and notices process.
However, if a Medicare Administrative Contractor (MAC) decides to revise more than just the ICD-10 codes, CMS is directing them to follow the regular LCD development process which can be found in Chapter 13 of the Medicare Program Integrity Manual. You can click on the link here http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/pim83c13.pdf to view this process on the CMS website.
Any LCDs and articles that do not contain ICD-10 information must be published on the Medicare Coverage Database no later than September 4, 2014.
Gina Tomcsik
Director of Compliance
Functional Pathways
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