ICD-10 Frequently Asked Questions

If you’re a HIPAA-covered medical professional, ICD-10 is a huge deal for you—like, deflategate huge. Along with all the controversy—including delays and grace periods—ICD-10 also has caused a lot of confusion. Over the course of the months leading up to the October 1 transition, we’ve received thousands of questions regarding the new code set. After sifting through your coding queries, we’d bet good money that thousands more folks have questions, but they’re afraid to ask. That’s why we gathered our very best answers to your most-frequently-asked questions and created this hefty, Costco-sized collection:

The Seventh Character Craze

What is the seventh character?

The seventh character didn’t exist in ICD-9, so it’s caused a great deal of confusion. Basically, it’s a mechanism for applying greater specificity to a diagnosis, particularly with regard to the episode of care. As its name would suggest, the seventh character should always be the seventh digit of a code. As this blog postdetails, there are three seventh characters related to the episode of care:

A (initial encounter) describes the entire period in which a patient is receiving active treatment for the injury, poisoning, or other consequences of an external cause.
D (subsequent encounter) describes any encounter after the active phase of treatment, which is when the patient is receiving routine care for the injury during the period of healing or recovery.
S (sequela) indicates a complication or condition that arises as a direct result of an injury.

How do I know when to use the seventh character?

You don’t always need to attach a seventh character to your diagnosis code. Seventh characters are required for codes in certain ICD-10-CM categories—primarily Chapter 19 (Injury, poisoning and certain other consequences of external causes) and Chapter 15 (Pregnancy, childbirth and the puerperium). You’ll know when to use it because there will be instructions specifying seventh character use within any code book or tabular list you reference. Don’t see instructions? Then “leave the seventh position blank,” explains this blog post. “Adding a seventh character to a code that does not require one will make the entire code invalid.”

What’s the difference between A (initial) and D (subsequent)?

We've seen multiple interpretations of what distinguishes an "initial encounter" from a "subsequent encounter." Based on everything we’ve reviewed, this is the best answer we’ve found: "The 7th character for 'initial encounter' is not limited solely to the very first encounter for a new condition. This 7th character can be used for multiple encounters as long as the patient continues to receive active treatment for the condition." This resource goes on to say: "The key to assignment of the 7th character for initial encounter is whether the patient is still receiving active treatment for that condition."

So, it appears that the words "initial" and "subsequent" have less to do with how many practitioners the patient has already seen or how many visits the patient has logged at your office, and more to do with the patient's treatment phase (i.e., "A" for active treatment and "D" for recovery/healing). That would mean the "A" designation wouldn't be limited to the patient's first visit, even though the label "initial encounter" makes it seem like a one-time descriptor.

What about sequela (S)?

According to Code It Right Online, “‘sequela’ in ICD-10-CM, is a chronic or residual condition that is a complication of an acute condition that occurs after the acute phase of a disease, illness or injury. It can also be caused indirectly by the treatment for the disease or condition.” There’s no time limit on when you can use sequela; “the residual condition may come directly after the disease or condition, or years later.” Simply put, this less frequently-used character is reserved for complications or conditions directly resulting from an injury.

For further insight on sequelae, check out this example from the AAPC: “A patient suffers a low back injury that heals on its own. The patient isn’t seeking intervention for the initial injury, but for the pain that persists long after. The chronic pain is sequela of the injury. Such a visit may be reported as G89.21 Chronic pain due to trauma and S39.002S Unspecified injury of muscle, fascia and tendon of lower back, sequela.” One caveat to this example: Don’t fall back on an unspecified code. Instead, ask the patient as many questions as possible to get to the root cause of the original injury.

How do I format a code that requires a seventh character?

As this post explains, “If you add a seventh character to a code with fewer than six characters, you must fill each empty slot with a placeholder ‘X.’” For example:

You choose S44.11, Injury of median nerve at upper arm level, right arm, for your patient.
You look at the instructions for the S44 code category and determine that you must add a seventh character to this code.
Because the patient is receiving routine care for the injury in the healing and recovery phase, you determine that D is the appropriate seventh character.
S44.11 is only five characters long, so you add an X in the sixth position.
You then add your seventh character of D, making the final diagnosis code: S44.11XD, Injury of median nerve at upper arm level, right arm, subsequent encounter.

Do I need to change the seventh character every time a patient returns for another visit?

Nope. You would only change the seventh character if the patient progressed to a different phase of treatment (i.e., the patient moved from the active treatment phase to the recovery/healing phase).

External Cause Codes

Do I have to use external cause codes?

As explained in this blog post, there's no national requirement mandating any provider—PTs included—to submit external cause codes. However, providers are encouraged to do so when possible. Furthermore, some state and regional payers may require the use of external cause codes, so check with each one individually.

What are external cause codes? And how do I use them?

Found in Chapter 20, external cause codes help give context to a particular diagnosis code, and contrary to the name, external cause codes can indicate more than cause. To appropriately apply accurate external cause codes, you'll also have to consider the place of occurrence, activity, etc. We recommend asking yourself the following questions regarding the patient's injury: How did the injury or condition happen? Where did it happen? What was the patient doing when it happened? Was it intentional or unintentional?

When do I use external cause codes?

If it’s possible to submit external cause codes for a particular category or section of codes, you will see instructions to do so within the tabular list. Also, bear in mind that you can never submit an external cause code by itself; it always must have a corresponding principal diagnosis code. Here's a quick clip to show you how to use external cause codes.

What if I don’t know what caused a patient’s injury or condition?

External cause codes are not mandatory (at least not nationally). Remember: you cannot code for what you don't know. So, if you don't know the details necessary to select external cause codes—like what caused the onset of the injury, the activity the patient was engaged in at the time of the injury, or where the patient was when the injury occurred—then don't submit any such codes.

The Great Switch

Do I need to complete a progress note, evaluation, or a re-evaluation to switch to ICD-10 codes?

No. Instead, when it comes time to add ICD-10 codes for the patients who previously had ICD-9, you'll simply update the diagnoses in the patients’ charts as they come in for appointments on or after October 1.

Will I need to mass-update my patient notes come October 1?

No, there’s no need for a sweeping code change for all your patient notes. You’ll simply update codes within patients’ charts as they come in for their visits.

What about the ICD-10 grace period?

There’s a lot of confusion regarding CMS’s “grace period.” According to CMS, “Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family.” That means ICD-10 absolutely is happening on October 1. You'll still receive denials from your commercial payers if you code inaccurately. And, for Medicare claims, you still have to code using valid codes from the accurate code family. For all of the details on what this grace period means for providers, check out this blog post.

The Resources

Where can I get an ICD-10 code book?

You can access the entire code set free of charge here.

Is there an ICD-10 cheat sheet for physical therapists?

We have a wealth of educational resources that you can download here. However, we wouldn’t recommend using a “cheat sheet.” As most providers know, certain CPT codes are only payable when used in conjunction with certain ICD-9 codes. Thus, you may be tempted to quickly crosswalk those ICD-9 codes and tack up a new reimbursement cheat sheet—or worse, download the first cheat sheet you find online. Don’t. The rules aren’t the same, and crosswalks typically yield unspecified ICD-10 equivalents. As this ICD-10 for PT article explains, “One of the main battle cries of the new code set is increased specificity, and the transition to ICD-10 represents a giant step away from the use of unspecified codes (unless one of those codes truly represents the most accurate description of a patient’s condition). Thus, if you submit an unspecified code when a more specific code is, in fact, available, you could put yourself at risk for claim denial.”

Do you have any ICD-10 information specific to hand therapy?

We recommend checking out this ASHT page.

Do you have any ICD-10 information specific to pelvic health?

We recommend checking out this resource.

Claims, Claims, Claims

How do I handle billing for services provided before and after October 1?

We recommend that practitioners finalize notes and get claims submitted for all dates of service prior to September 30 before October 1 hits. That way, you’re able to start with as clean of a slate as possible come October 1. For additional info on dual coding, check out this post.

Are the 1500 forms going to change? How many ICD-10 codes will be allowed on the 1500 form, and how should I order them?

HCFA 1500 forms were updated in 2013 to accommodate ICD-10, so you shouldn't have any problems there. You can list up to 12 ICD-10 codes. Keep in mind, though, that only the first four can be linked to CPT codes. Thus, it’s imperative that you arrange the ICD-10 codes in order of importance, with the codes that best justify the medical necessity of your services appearing at the top.

How will ICD-10 affect CPT codes (e.g., 97001, 97110, and 97140)?

ICD-10 does have a set of procedure codes, but anyone who currently uses CPT codes to designate procedures will continue to do so. So, if you're using CPT codes, ICD-10 will not change that. You can continue using CPT codes as you do now, even after October 1.

Compliance

How does ICD-10 work with therapy cap exception codes?

There haven't been therapy cap exceptions for a while now. In 2014, Medicare introduced a two-tier exceptions process. In the first tier, which is the Automatic Exceptions tier, therapists affix the KX modifier to necessary services provided above the cap amount. To learn more about the therapy cap, check out this guide.

How does ICD-10 affect the KX modifier?

It doesn’t. You will continue using the KX modifier to denote automatic exceptions in the same way you currently use this modifier.

Will ICD-10 affect G-codes?

ICD-10 will not affect functional limitation reporting (aka G-code reporting). The current rules will still apply after October 1.

Documentation

How do I handle direct access patients in ICD-10?

We’ve received tons of questions about how to choose the most accurate diagnosis codes for non-referral patients. For advice at every stage of the entire code selection process, check out this blog post.

Keep in mind, though, that this advice isn’t purely for direct access patients. Just because you receive a diagnosis code from a referring provider doesn’t mean you can accept that code blindly, plug it into your documentation and your claim forms, and expect to get paid. You should use the physician diagnosis to inform you on the patient’s situation, but then use your own clinical judgment and skills as a medical professional to diagnose the patient based on what you’re actually going to treat. To learn more about selecting diagnosis codes that help justify treatment, check out this blog post.

What’s the difference between medical diagnosis and treatment diagnosis?

The treatment diagnosis is the one that represents the injury or condition that you, as the therapist, are treating. The medical diagnosis is typically the one that comes with a referral patient's script. Usually, the treatment and medical diagnoses match. If they don't, it's a good idea to get the physician to sign off on the treatment diagnosis before you bill.

Are there V codes in ICD-10?

ICD-9's V codes will become Z codes in ICD-10, but as explained in this blog post, "A simple mapping of the V57 series of codes found in ICD-9-CM over to ICD-10-CM is not possible, as codes that duplicate the V57 series currently are not included in ICD-10-CM classification." Furthermore, because V57.1 does not provide specific, detailed information about the patient's diagnosis—and thus, does not justify the medical necessity of the treatment—using a similar code in ICD-10 could lead to claim denials. Instead, you should select whatever code explains the patient's diagnosis in the most specific way possible. For more on the importance of coding for medical necessity, check out this blog post.

How do I code for surgical aftercare?

As explained in this resource, the aftercare Z codes should not be used for aftercare of injuries/fractures where seventh characters are provided to identify subsequent care. That said, you won't always be providing aftercare for injuries—especially in cases involving surgical aftercare. For that reason, ICD-10 contains a few options for coding for surgical aftercare. A couple examples: Z51.89, Encounter for other specified aftercare, and Z47.1, Aftercare following joint replacement surgery. Please note that when you use aftercare codes, you also should code for any underlying conditions/effects. Codes for bone, muscle, and joint conditions that are chronic or recurrent—or that result from a healed injury—are typically found in chapter 13. Also, if you're coding for joint replacement aftercare, you should include a code indicating which joint was replaced (e.g., V43.65, Joint replaced, knee).

What if I don’t have enough information to select a more specific code?

Select the most specific code you can based on the information you have. In some cases, you may need to contact a referring provider for additional information. But if you’ve exhausted all options and still can’t obtain the information necessary to select a more specific code, just make sure you clearly document the reasons behind your code selection within your documentation.

What if a more specific ICD-10 code does not exist?

ICD-10 requires you to code as specifically as possible, but there may be instances in which codes for your specific diagnosis do not exist, and you'll have to use an unspecified or generalized code. You can't code for what you don't know; just make sure you communicate all the details in your documentation. To learn more about when to use unspecified codes, check out this blog post.

Do I remove codes as my patient improves?

If the patient's primary diagnosis changes, and you need to update the plan of care, then you should update the diagnosis code. However, if the patient is simply making progress, you can document his or her progress as normal.

How many ICD-10 codes do I have to add for each patient?

There is no minimum or maximum number of codes you can record (though not all will necessarily flow through to your billing, and obviously, you will need to enter at least one). Just make sure you order the diagnosis codes you do submit in order of importance, with the primary diagnosis at the top.

Can’t I just use the ICD-10 code I receive from the referring physician?

Because clinical judgment is such a crucial part of selecting the appropriate diagnosis code, the therapist may need to get involved with code selection to ensure that:

The selected code is the most specific one available to describe the patient's condition, and
The code justifies the medical necessity of the services provided.

In some cases, the codes sent by referring physicians may meet that criteria, but ultimately, it's your clinic's responsibility to code correctly. After all, it’s your clinic—not the physician’s—that will end up suffering the consequences for inaccurate coding. Don’t just take the physician’s word as gospel. Your physicians don’t have the depth of neuromuscular knowledge and expertise that you do. You are best equipped to make the most specific diagnosis possible, and that is exactly what ICD-10 requires.

How do I code for multiple body parts?

For single conditions involving multiple sites, such as osteoarthritis, there often is a “multiple sites” code available. If no “multiple sites” code is available, you should report multiple codes to indicate all of the different sites involved. For a patient seeking treatment for multiple conditions involving multiple body parts, you would create separate cases just as you do with ICD-9.

If a patient is experiencing the same condition on both sides (i.e., right and left), how do I code for that? I noticed some ICD-10 codes don’t have “bilateral” options.

In some categories and families of codes, there is no "bilateral" option for denoting laterality. In those cases, you would need to submit separate codes for both the left and the right sides. This is for data-tracking purposes (e.g., tracking the total number of "left" and total number of "right").

If a patient has multiple diagnosis codes, which one should be the primary diagnosis?

Your primary diagnosis code should be the one that most closely aligns with the reason the patient is seeking your services. From there, you should order the codes according to importance and significance regarding medical necessity.

Whew! That was a lot of information, right? Hopefully, it helped ease your mind. But remember these are the answers to only your most burning questions. Need more ICD-10 advice? We’ve got your back. Check out these posts—and tons more—on the WebPT Blog:

Do you have more ICD-10 questions that weren't answered here? Please visit icd10forpt.com for more.