Lesser ICD-10 impact this year, but maybe not so for LCDs

Nov. 20, 2017 / By Divya Verma, RHIA

When 2018 ICD-10 codes were implemented this October 1, I hoped that ICD-10 related Local Coverage Determination (LCD) updates would be fewer as compared to last year’s updates. Due to the partial ICD-10 code freeze lasting until Sept 30, 2016, there were large numbers of new ICD-10 codes added in 2017 (see Table 1). Hence, there was a high volume of LCD updates for October 1, 2016. This year, however, Medicare Administrative Contractors (MACs) began posting hundreds of LCDs and articles effective October 1, 2017 as “Revisions Due To ICD-10-CM Code Changes.” This made me curious: Why so many updates when ICD-10 changes are so few?

Table 1: Number of ICD-10s changes for each year

These annual ICD-10 updates to LCDs consist of new code additions, deletions of expired codes and revisions to existing codes in the policies. So, I looked at total ICD-10 CM updates (additions, deletions, revisions) for each update year. There were 2,710 changes for October 1, 2016 and only 728 changes for October 1, 2017 (see table 1). 

I then gathered data from the CMS Database for two randomly selected MACs. Table 2 below shows the number of Part A LCD updates as a result of annual ICD-10 updates for 2016 and 2017, along with the total number of LCDs for each of the two MACs.

Table 2: Number of part A LCD updates due to annual ICD-10 updates for each year for two of the MACs.

Inferring from Table 2, it looks like a slightly larger number of LCDs were updated for this year than last year for each contractor, but this finding doesn’t closely correlate with the volume of code updates for a given year.

So why were there so many LCD updates this year due to ICD-10 revisions? Putting volume of updates aside, I did some digging into chapter-wise ICD-10-CM changes for the last two years. Out of a total 21 ICD-10 CM chapters, all except Chapter 1 were revised for October 1, 2016. For October 1, 2017, all chapters except Chapter 3 and 8 are revised. LCDs are created to establish coverage criteria for a broad number of services like cardiology procedures, gastrointestinal procedures, neurological procedures, ophthalmology procedures, urological procedures, pulmonary procedures, psychiatric procedures, physical and occupational therapy services, lab tests, drugs uses in oncological and non-oncological conditions, radiology tests for various anatomical parts, and so on. ICD-10 CM chapters are also structured system wise, for example, diseases of circulatory system, digestive system, nervous system, eye and adnexa, genitourinary system, respiratory system, mental disorders, neoplasms, injuries of various body parts, and so on. Therefore, altogether these LCDs list ICD-10-CM codes from various chapters. Revisions to most of the ICD-10-CM chapters, regardless of volume, still mean revisions to more LCDs. This explains why the number of LCD updates remained almost the same for each year due to ICD-10 revisions.

Additionally, some of these LCDs list a massive number of ICD-10-CM codes from several ICD-10-CM chapters, thereby increasing their chances of annual updates. For example, JN MAC Part A LCD Magnesium with 3,760 ICD-10 CM codes and Electrocardiography with 4,475 codes are likely to be impacted every time with code updates as they have codes from many ICD-10-CM chapters. Even a policy Interspinous Process Decompression with only one code (M48.06- Spinal stenosis, lumbar region) is impacted this year, as this code is now replaced with two more specific codes (M48.061– Spinal stenosis, lumbar region without neurogenic claudication; and M48.062- Spinal stenosis, lumbar region with neurogenic claudication).

ICD-10 codes in LCDs are constantly updated not only in annual ICD-10 CM updates but also for:

• Removal of less specific codes
• New reconsideration requests
• New FDA approved conditions
• Conditions no longer covered by Medicare
• National policy updates

These LCDs are also revised for various other reasons like

• CPT/HCPCS code updates
• Modifier updates
• Frequency and sex restrictions updates
• Documentation requirements updates
• Utilization guidelines updates

New LCDs are created for new tests, new technologies, and newly identified risk areas. Old policies are retired when they no longer serve the intended purpose.  

As time goes by, we should see fewer ICD-10 code updates each year. However, LCDs will continue to be updated annually at a similar pace. It is the responsibility of a Medicare provider to keep up to date with changes to these LCDs and other documents related to medical necessity or claim payments might get delayed, denied or audited.

[NOTE: Links and data in this blog are as of November 1, 2017 from Medicare Coverage Database and are subject to change.]

Divya Verma, is a compliance analyst for the Medical Necessity and Compliance division within 3M Health Information Systems.

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Resources

1. 2018 ICD-10-CM and GEMs.
2. Local Coverage What’s New Report.
3. Local Coverage Determinations (LCDs) Status Report.
4. Local Coverage Determinations (LCDs) by Contractor Index.
5. What is a MAC and what do they do?
6. JN MAC Part A LCD Magnesium.
7. JN MAC Part A LCD Electrocardiography.
8. JN MAC Part A LCD Interspinous Process Decompression.