Those who have already bought the posters  are in 100% compliance with the posting requirement.   This new posting is still expected to go into effect … just at a later date than expected.

Posters ordered at this time are in compliance with the requirement that nearly all private-sector employers  notify employees of their rights under the National Labor Relations Act (NLRA) by posting a notice.

If you’re interested in following the AMA’s activities around this issue, start here (scroll down to the paragraph labeled “Stop the Implementation of ICD-10″), then check their Web site regularly for updates. Read an article from Medscape Today News about the AMA’s action here. (You’ll have to sign up for a free account to access Medscape, if you don’t already have one.)

For the view from the U. S. Department of Health and Human Services, visit the Centers for Medicare & Medicaid Services (CMS information page here. At this site you can sign up for e-mail updates and follow the CMS on Twitter.

The AAPC, an association founded in 1998 to provide education and certifications for professional coders, offers good information on their Web site. The organization offers two-day trainings around the country as well as on-site training and assessments to help practices prepare for next October.

The American Health Information Management Association (AHIMA) Web site features extensive information on the transition to ICD-10, including a comprehensive FAQ section that you may find helpful. This organization also offers educational seminars, a wide array of webinars and publications (some for free, some for purchase) and a list of available trainers.

For ICD-10 information that is more specific to your practice, check with the specialty associations (American College of Physicians, American Association of Family Physicians, American College of Surgeons, etc.). Your local county or state medical society should also have information on local resources and training. This is a good time to make use of your association and professional organization memberships.

The National Labor Relations Board has recently issued a rule that requires nearly all U.S. businesses to post a notice to employees communicating their rights under the National Labor Relations Act. Covered employers must replace their federal poster by November 14, 2011, to remain in compliance.

The new posting is mandatory regardless of your company’s union status. It applies to both union and non-union workplaces alike.

The easiest and most effective way to protect your business is with the ComplyRight™ Federal Poster. This convenient all-in-one poster includes the new NLRB notice and the six other mandatory federal postings. Another option is the ComplyRight Federal and State Kit. This poster set meets every federal and state requirement to keep your business in full compliance.

The deadline to comply is November 14. A word of caution: Noncompliance can be treated as an “unfair labor practice” and can be used as damaging evidence in a lawsuit.

Below is a list of Frequently Asked Questions about the situation.

FAQs

Q: What if my business is non-unionized? Do I still have to comply?
A: Yes, this new poster is mandatory regardless of your company’s union status. It applies to union and non-union workplaces alike.

Q: You said “nearly” all employers have to post the new notice. What are the exceptions?
A: At this time, the requirement does not apply to agricultural, railroad or airline employers — or the U.S. Postal Service. In addition, some very small businesses and retailers may be exempt. If you believe your company falls into this category, confirm with your accountant or financial professional. Noncompliance can be treated as an “unfair labor practice” and can be used as damaging evidence in a lawsuit. 
 
Q: Is this a separate posting?
A: No, it is included on the federal poster with the other required notices, such as OSHA, Federal Minimum Wage, etc.

Q: How large is the poster?
A: The laminated poster is 24” x 32.75”.

Q: Is there an electronic posting requirement?
A: Yes, if you typically post company policies on an Intranet or Internet site, you must post this notice there as well. Our poster includes a URL where you can download a free electronic copy. The URL is contained in an employer note on the printed poster.

Q: Do I need to post this in Spanish?
A: This notice must be posted in other languages if 20 percent or more of your workforce is not proficient in English. The Spanish version of the NLRB posting is included on the ComplyRight™ Spanish Federal Poster.

Q: What is the fine for not posting?
A: There is no specific fine connected with this posting. However, noncompliance can be treated as an “unfair labor practice” and can be used as damaging evidence in a lawsuit. There are fines, however, attached to the other required federal postings — OSHA, for example. You can be fined up to $17,000 per location for not displaying current federal notices.

To order Florida prescription blanks click here.

On December 8, 2010 Congress passed legislation that exempts physicians from the FTC’s Red Flag Rules. For more information on you can visit the Physicians Practice blog at: http://www.physicianspractice.com/blog/content/article/1462168/1752034

Copyright© 2010 by UBM Medica. www.PhysiciansPractice.com All rights reserved.

By Deborah Grider

It is now only 37 months before ICD-10-CM becomes a reality. There’s much to do before October 1, 2013, but implementation can be a smooth transition if you take a systematic approach. There are many elements that need to be addressed, but preparing your practice in a step-by-step fashion can keep the transition from becoming overwhelming.

Planning and implementing ICD-10-CM must include communication and significant collaboration on information technology, finance, education, and problem solving. The work necessary to implement ICD-10-CM and the resources required will depend on the size of the practice. A large practice may need to recruit key people from many different departments and areas of the practice to assist with the transition; a small practice might enlist only one or two staff members to assist in the transition.

Version 5010
The transition to Version 5010 of the Electronic Data Transactions (EDI) must be made no later than January 1, 2012 — prior to ICD-10-CM implementation. Version 5010 must be implemented because Version 4010A cannot accommodate the expansion of the code sets that include ICD-10-CM and ICD-10-PCS. You will not be able to send claims or receive reimbursement without the 5010 conversion.

You’ll need the help of your software vendors to make this transition. My advice is to contact them now because level I testing (the vendor’s internal testing) also should be happening now. Make sure the software conversion occurs prior to January 1, 2012, in case there are problems with the conversion that must be fixed prior to the “drop dead” date.

Organize implementation
Every practice needs to assign a project team or key person to organize and manage the implementation effort. If you have several people in your practice involved in the ICD-10 transition, form a team and assign projects with completion dates during each step of the process. The transition team or key person is responsible for the initial planning process.

Include at least one physician in the implementation process, as well as your management and coding staff. It’s important to have the physicians involved so they understand the importance of preparation as the transition occurs. Ask the project team to provide periodic progress reports so everyone is aware of the progress, problems, and barriers to implementation in your practice.

After leadership roles have been identified, it’s time to get to work. The first step is preparing a project summary, including an overview description of the regulation, changes to the code set, the anticipated scope of work that needs to be accomplished, and anticipated internal and external work processes. For larger practices this could mean reading the ICD-10 final rule; for smaller practices this could mean reading materials prepared by a professional society. The project summary, along with an outline of project steps, will serve as the roadmap for completing the implementation. This summary should be shared with the physicians in your practice.

Impact analysis
A preliminary impact analysis is a good tool for assessing which areas of your practice may be affected most in the early stages of ICD-10-CM implementation. After the analysis is complete, the project team can develop a budget for ICD-10-CM implementation. Vulnerable areas may include:

• Information systems

• Documentation

• Staff education needs

• Clinical and administrative areas

This information must be shared with the providers so they understand the depth of the changes. It is important in this planning stage to identify who in the medical practice or organization has decision making authority.

Information systems
Conducting a system audit for ICD-10-CM compatibility is part of the impact assessment. Start by performing a comprehensive audit of all data systems currently using ICD-9-CM, and then analyze the systems that will use ICD-10-CM. Your analysis should answer the following questions:

• How are ICD-9-CM codes currently used in information systems?

• Which vendor software applications are being used?

• How are codes entered? Are they manually entered or imported from another system or software?

• Can the system handle alphanumeric structure? It must be able to.

• Can the codes, code descriptions, and supported documentation be obtained in a machine-readable format?

• Does the code format include a decimal?

• Can the current system house both ICD-9-CM and ICD-10-CM codes simultaneously?

• How is the quality of data checked?

• How do the systems interface?

After you perform a comprehensive audit of the IT systems, perform an analysis of necessary changes to be implemented for the transition to ICD-10-CM. Identify which forms and reports will need to be reformatted or revised. Evaluate whether each system’s storage capacity is sufficient to support both ICD-9-CM and ICD-10-CM during the transition, or if the capacity will need to be increased. Also consider how long ICD-9-CM will be accessible, which staff will need to access ICD-9-CM, and how long the legacy data will need to be available.

System vendors
Contact system vendors during this phase to determine whether they can support legacy and new coding systems, and for how long. This is an ideal time to identify costs for upgrading software and storage capacity, as well as contract issues with the vendor. Other potential vendor costs may include hardware upgrades, customization, staffing, and overtime.

Determine if upgrades are included in the current contract or if there will be additional costs to upgrade. Coordinate with the vendor to create the timeline for testing and installation of the new or upgraded software or system. Other IT system considerations might include a conversion to an EHR during this transition, if the organization hasn’t previously converted.

Documentation
Because ICD-10-CM is more robust (with up to seven digits of specificity), assess whether documentation currently in your medical records will support the level of specificity necessary for ICD-10-CM.

The organization should have an experienced auditor conduct audits either internally or externally. Random samples should be evaluated and various types of medical records should be reviewed. A clinical documentation assessment tool should be used to conduct this audit to be sure current documentation adequately supports ICD-10.

When an audit has been conducted and analyzed, the practice will have a good assessment of any deficiencies, and can develop a priority list of diagnoses requiring more detail. The audit also helps identify providers who will benefit from focused training using ICD-10-CM.

Coding and billing education
Everyone in the medical practice will need some form of training. Physicians, nonphysician providers (NPPs), coders, and billing staff will need more extensive training than ancillary staff (nurses, MAs, managers, etc.).

Questions to ask:

• How much training on ICD-10-CM will be necessary?

• How many training days will be required?

• Will there be lost revenue if the practitioners need to be out of the office for training?

• How will productivity be affected?

• How much training does each staff person need?

Some studies indicate that less than 16 hours of training is necessary on ICD-10-CM. The reality is that physicians will need approximately 16 to 20 hours of training, coders will need 40 to 60 hours of training, and other staff might need approximately six to 10 hours of training.

Finances
Because reimbursement is tied to procedural and diagnosis coding, your practice’s finances will be affected greatly by the transition. For example, after the implementation date, if an insurance carrier cannot accept ICD-10-CM codes, your practice probably will not be paid by that insurer. Make sure you know which of your payers have fully transitioned to ICD-10-CM and which have not, so you can do your billing accordingly to ensure you get paid.

Review the current reporting for procedures and services using ICD-9-CM and compare them to ICD-10-CM codes. Professional services are paid based on the procedure code, but the diagnosis code supports medical necessity — the driving factor in payment for all medical procedures and services.

Reports tied to diagnosis codes, such as the accounts receivable analysis, pending claims reports, analysis by provider type, and collection reports also will be affected. Assess which reports will be affected by the ICD-10-CM transition and what changes will need to be made.

Post implementation
The impact of the ICD-10-CM transition on your practice will not end on the October 1, 2013. Pended or denied claims are expensive, and generally are dealt with through a manual process. Any increase in the number of claims not processed or paid will first decrease provider cash flow, then increase both provider workload and plan workload to process the denials. To reduce the risk of reduced cash flow, providers and staff need to know and understand the changes in documentation and coverage requirements well ahead of time to adapt in time for implementation.

It is a fact that people’s productivity decreases short term when they are in training or learning a new skill. These slowdowns result in loss of productivity, including charge capture and reimbursement, and can affect the financial health of a practice. Anticipate a decrease in productivity by measuring and analyzing the impact of the transition prior to beginning the training process. Planning ahead also allows you to try a staggered training approach, where one group of providers and staff is trained at a time, helping to limit the impact on productivity.

Analyzing all areas affected by ICD-10-CM and making operational changes within your practice to accommodate the new code set will ensure a smoother transition to ICD-10-CM. Thirty-seven months may seem like a long time away, but successful implementation depends on planning ahead and allowing time for resolving issues with vendors, equipment, documentation, and training. Getting started now means less stress later in the process.

Copyright© 2010 by UBM Medica. www.PhysiciansPractice.com All rights reserved.