The American Health Information Management Association has launched a campaign opposing H.R. 2652, the Protecting Patients and Physicians Against Coding Act.

The bill, introduced by Rep. Gary Palmer (R-Ala.), would establish a two-year “grace period” for accepting codes submitted once the October 1 ICD-10 implementation deadline goes into effect. During this time, providers could not be denied Medicare/Medicaid payments because of coding errors. AHIMA is urging members to contact their congressmen and senators to “let them know you oppose any legislative efforts to reduce the accuracy of medical coding.”

Also See: House Bill Seeks ICD-10 Grace Period

AHIMA argues that the proposed grace period “goes too far” and has the potential to lead to waste, fraud and abuse. “With no official repercussions for inaccurate coding the door is wide open for both improperly paid claims at best and rampant fraud at worst-since proper payment of claims depends on accurate coding,” according to the association. “Coverage determinations and validation of medical necessity of healthcare services depend on codes submitted on claims for reimbursement; this bill is written in a manner that leaves the door open for up coding and possibly outright fraud.”  

In addition, AHIMA asserts that Palmer’s legislation is unnecessary given there already are mechanisms built into medical coding to allow for less specific codes when necessary and appropriate. For example:

* There are “unspecified” codes in both ICD-9 and ICD-10;

* Unspecified ICD-9 codes are already allowed in Medicare fee-for-service payment systems;

* There is no indication that allowance of unspecified codes will change under ICD-10, and;

* There are also “default” codes when there is no “unspecified” option. 

The organization also makes the case that the bill is “unnecessary since CMS end-to-end testing has shown that only two percent of claims were rejected due to ICD-10 coding errors during the most recent testing period, which ran April 27 to May 1,” which is “actually lower than the number of claims, 3 percent, currently rejected by CMS after annual ICD-9-CM code updates.”

Nonetheless, in a unanimous vote at its annual meeting earlier this month in Chicago, the American Medical Association House of Delegates supported the establishment of a two-year grace period for ICD-10 “during which physicians will not be penalized for errors, mistakes and/or malfunctions of the system.” AMA also wants hardship exemptions for physicians whose billing software or claim clearinghouse service are unable to smoothly transition to the new code set.

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