As the newly-appointed ICD-10 ombudsman, William Rogers, M.D., is the internal advocate within the Centers for Medicare and Medicaid Services charged with investigating and addressing stakeholder complaints and problems they might encounter starting October 1—the compliance deadline for the new code set.
Should the code switchover go south and Medicare claims be rejected in droves, Rogers’ email—firstname.lastname@example.org—will no doubt become the ICD-10 equivalent of dialing the 9-1-1 emergency number for providers in trouble.
“I certainly understand the anxiety that docs in small practices and hospitals are feeling because the disruption of cash flow for many can be a near-death or death experience, and we want to make sure that doesn’t happen,” says Rogers, who acknowledges it will be “a rocky couple of months” once the ICD-10 deadline goes into effect.
During those couple of months, Rogers expects the agency will “be busy figuring out what belongs to CMS and what belongs to the Medicare Administrative Contractors, the people that actually process the claims.” However, he hastens to add that soon after “it will be business as usual and we will have survived.”
CMS has staffed a new ICD-10 Coordination Center located in Baltimore, Md., which will be responsible for managing and triaging coding issues that arise. “We’ll have to make sure that we’re staffed up for that and we move quickly to get those things addressed,” says Rogers, who describes himself as “one of the touch points for activating the center.”
In announcing Rogers’ appointment as ICD-10 ombudsman, CMS Acting Administrator Andy Slavitt referenced the fact that he is an attending ER physician at Georgetown University Hospital in Washington and is a colonel in the U.S. Air Force serving as a state air surgeon. A practicing emergency room physician for 30 years, Rogers is no stranger to the ombudsman role.
Since 2002, he has served as director of the Physicians Regulatory Issues Team at CMSinan ombudsman capacity in which he has sought to reduce the regulatory burden on clinicians who participate in the Medicare Program. By his own admission, taking on the ICD-10 ombudsman responsibilities was “natural” for him given his more than a decade of experience at CMS, yet he readily admits that he is not a medical coding expert.
“The only thing worse than being able to help is not being able to help, and so I welcome the opportunity to try and make this as painless and as seamless as possible,” comments Rogers, adding that his email address is being closely monitored by CMS staff in Baltimore. “We have wisely deployed a pretty good size army of people to get us through the first couple of months. And, I’m grateful for that because it really is going to be time intensive and people intensive for a few months.”
He believes his role with regard to ICD-10 is similar to what it’s been previously at CMS, namely to “organize solutions to major problems and to be a sounding board for affected people out there in the provider communities.” Also, Rogers sees himself as being a “vigorous advocate” in those instances in which CMS staff might not understand the “gravity” of a problem.
According to Rogers, until the first Medicare claims are rejected in about mid-October, “nobody is going to know how much of a problem they have.” Claims dated October 1 will take some time to be processed, he argues, adding that “there will be a little delay there before people realize they have a problem.”
Some industry observers have compared the ICD-10 code switchover to the Y2K bug, a problem in the coding of computers that was predicted to create havoc with networks at the beginning of the year 2000. However, few major failures occurred in the transition from December 31, 1999, to January 1, 2000. Likewise, Rogers believes ICD-10 has been overblown in terms of “doom and gloom” scenarios.
“I was running an ER in those days and the hospital wanted me to be there to monitor the Y2K transition. I said: ‘You know what? I’m going to a New Year’s Eve party—this is going to be fine,’” he recalls. “Actually ICD-10 scares me a lot less than Y2K when we were talking about nuclear reactors and power grids potentially going down. This is a very different animal.”
When it comes to the ICD-10 readiness of CMS systems, Rogers gives the agency a clean bill of health, pointing to a Government Accountability Office audit released earlier this year which conducted its own independent assessment of CMS’s preparations for the code switchover and concluded that Medicare fee-for-service claims processing systems are ready.
The GAO “doesn’t pull any punches,” he says, “and they are very comfortable that there is not going to be a problem on our side of the transaction.”
Nonetheless, a GAO report released late last week concluded: “While CMS’s actions to update, test, and validate its systems, and plan for contingencies can help mitigate risks and minimize impacts of system errors, the extent to which any such errors will affect the agency’s ability to properly process claims cannot be determined until CMS’s systems begin processing ICD-10 codes.”
Some critics of the agency are not convinced that CMS systems will perform as they should with ICD-10. Rep. Michael Burgess (R-Tex.), M.D., a member of the House Energy and Commerce Subcommittee on Health, has charged that “anytime CMS flips a switch and it involves the processing of data their systems fail,” referencing its botched implementation of the Healthcare.gov website.
“Everyone remembers the Health Insurance Marketplace, but the comparison to ICD-10 is not at all accurate,” asserts Rogers.“Compared to that project, this is simple. This is not complicated.”
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