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Coalition for ICD-10 Statement on H.R. 3018, “Coding Flexibility in Healthcare Act”

The Coding Flexibility in Healthcare Act (H.R. 3018) introduced by Representatives Marsha Blackburn and Tom Price would allow either ICD-9 or ICD-10 codes to be submitted on claims with dates of service after October 1 (i.e., “dual coding”) for a six-month period. In a press release, Rep. Blackburn indicated that a transition period allowing the use of either ICD-9 or ICD-10 codes is needed in the event that some physicians’ practices software is not ready to support ICD-10 by October 1. Similar comments have been made by supporters of H.R. 3018 (see Medical Group Management Association letter). However, dual coding is unworkable and costly, as well as unnecessary.

If a provider is unable to submit ICD-10 claims electronically on October 1, there are a number of available claim submission options. Health plans have active outreach programs and are working with their respective provider communities to address issues and concerns, so providers concerned about their systems not being ready to submit claims on Oct. 1 should check with their local health plans or CMS for guidance. Medicare offers these billing options:

  • Free billing software that can be downloaded at any time from every Medicare Administrative Contractor (MAC);
  • In about half of the MAC jurisdictions, Part B claims submission functionality on the MAC’s provider internet portal;
  • Submitting paper claims, if the Administrative Simplification Compliance Act waiver provisions are met.

Additionally, providers can reach out to billing service companies or contact the Healthcare Billing and Management Association to find a billing service company that can assist them with submitting ICD-10 compliant claims.

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