In the run-up to the October 1 ICD-10 compliance deadline, there has been a lot of discussion about how the code switchover will affect ill-prepared hospitals and physician practices, but little attention has been given to home health agencies.

Home health software vendor Axxess warns that agencies that have not performed due diligence in preparing for ICD-10 will suffer significant negative financial and administrative impacts , including claim denials, delayed payment, and reduced cash flow. Likewise, healthcare consultant DecisionHealth concludes that “all corners of healthcare are affected by ICD-10, but no providers have more at stake than home health agencies.”

According to DecisionHealth’s Tricia Twombly, due to a unique reimbursement cycle, home health has had to transition to ICD-10 nine weeks earlier than the rest of the industry. Home health is reimbursed on a 60-day episode which requires two different time points of billing. Consequently, Twombly argues that the transition to ICD-10 for home health agencies was actually August 3—not October 1—with mandatory dual coding.

Melinda Gaboury, CEO of consultancy Healthcare Provider Solutions, similarly makes the case that August 3 would have been the first start date of a 60-day episode that, if the episode goes the full length, will end October 1. “The bottom line is that dual coding needs to be applied to any benefit period which may span the 10/01/15 deadline,” says Gaboury. “Claims billed with date of service prior to 10/01/15 will need to be billed with ICD-9 codes and claims, perhaps in the same benefit period, with dates of service 10/01/15 and later will need to be billed exclusively with ICD-10 codes.”

It’s interesting to note that during ICD-10 end-to-end testing conducted Jan 26-Feb. 3, 2015 by the Centers for Medicare and Medicaid Services there were no reported issues identified and zero rejects due to front-end CMS systems. However, in the area of institutional claims, there was one issue identified related to system edits: home health claims with dates that spanned the October 1, 2015, implementation date were not processed correctly and contained ICD-10 codes but were returned to the submitter. At the time, CMS stated that it impacted less than 10 test claims. 

Also See: CMS Touts Success of ICD-10 End-to-End Testing

To help avoid these kinds of claims denials, Axxess makes the case that home health agencies must create a transition plan, train staff on the new medical codes, and ensure that their software is designed to function properly in the code transition. The company earlier this week released a new white paper, ICD-10-CM Transition – Prepare for Cash-Flow Impact, which can be downloaded here.

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