The Centers for Medicare & Medicaid Services (CMS) updated its ICD-10 transition guidance ahead of the October 1 deadline when all practices are required to start using the new diagnosis codes. The CMS and physician associations, including the CAP, will be monitoring the implementation of ICD-10 and continue to offer resources to providers.

Physicians and health care providers are to begin using ICD-10 codes when billing claims with dates of service on or after October 1, 2015. In July, the CMS and the American Medical Association (AMA) released a joint statement announcing flexibility for 12 months in the claims auditing and quality reporting processes following the ICD-10 transition. In response to questions from the health care community, the CMS released Clarifying Questions and Answers Related to the CMS/AMA Joint Announcement and Guidance Regarding ICD-10 Flexibilities that provides answers to the most commonly asked questions. On September 22, the CMS reissued these questions and answers with revisions to questions one and nine, as well as nine new questions and answers.

For instance, the CMS stated that its guidance does not change coding guidelines. Its guidance detailing the yearlong flexibility also only applies to Medicare fee-for-service claims and not Medicare Advantage plans. The CMS ICD-10 Ombudsman William Rogers, MD, will field queries on issues raised by all health care providers and suppliers during implementation. Providers can send their questions via email.

The CMS also posts updates on ICD-10 on the agency's blog. In response to concerns by the AMA and physician specialty societies, the CMS also developed a website where providers can address their concerns with their respective Medicare Administrative Contractors (MACs) if they think a local coverage determination (LCD) contains any ICD-10 coding errors.

CAP Resources for Pathologists

The CAP has several resources on the ICD-10 transition available to members. CAP Practice Management has several documents for pathologists and practice managers (login required). Access the CAP's archived webinar from May 21 on ICD-10. CAP members can email the College for their practice management questions.

The CAP also will also provide a forum on CAPConnect to provide pathologists and pathology practices a place to ask questions, provide answers, and share stories on how this change is impacting your practice. Both members and practice manager forum participants can use this forum.

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The CAP published its initial analysis of the CMS' proposed changes to the Medicare Clinical Laboratory Fee Schedule (CLFS) on September 25. In case you missed the CAP's initial coverage, read the CAP STATLINE Special Report "CMS Proposes Deadline Delay for CLFS Data Collection, Sets Exemptions in PAMA Rule." The CMS estimates that the proposed rule will result in $360 million less in Medicare payments for CLFS tests furnished in fiscal year 2017, with a five-year impact estimated at $2.94 billion less and the 10-year impact is expected to result in $5.14 billion less in program payments.

With the breadth and complexity of the rule, the CAP had engaged with the CMS on implementation of the reforms to the CLFS prior to the proposed rule's release in an effort to educate and inform of possible implications on laboratories. The CAP will continue to advocate on areas of concern that remain in the proposed rule. The CLFS reforms were set by the Protecting Access to Medicare Act (PAMA) signed into law on April 1, 2014. Amongst its most significant provisions, the PAMA law requires applicable clinical laboratories to report private payor payment amounts and volumes for laboratory tests to the CMS. The data would be used to determine Medicare's payment for lab tests beginning January 1, 2017.

The CAP will report more information on the proposal and its analysis in future editions of STATLINE. Formal comments are due to the CMS by its November 24 deadline.

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Following the publication of the Institute of Medicine (IOM) "Improving Diagnosis in Health Care" study, the CAP will host a presentation on the report and its recommendations during CAP '15.

CAP Governor Emily E. Volk, MD, FCAP, and Michael B. Cohen, MD, FCAP, who served on the IOM study committee, will discuss the report on Monday, October 5 at 5:30 PM ET. Dr. Volk and Dr. Cohen will also be joined by Bibb Allen, MD, FACR, chairman of the American College of Radiology (ACR) Board of Chancellors.

The IOM study recommended greater pathologist integration into the health care team and additional payment mechanisms for diagnostic physicians, including pathologists. The CAP was one of the sponsors of the study examining the issue of diagnostic errors, which the IOM committee had been evaluating for nearly two years. The CAP supports efforts to prevent errors in all stages of the testing process and works to ensure quality tests for patients.

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