A smart user has asked: “Our system does not have the new codes effective 10/1/2008 loaded yet. Can I still use the old codes?”

The short answer is: there is NO grace period.

WK strives to deliver coding content as quickly as possible, and certainly before the effective date. Generally, content is posted to ChargeMaster comply within 48 hours, and to the coding tools and codebooks within a week. This can be difficult when CMS publishes data late. Please feel free to e-mail with any questions!!

If you want the long answer, keep reading:First, lets be clear about some effective dates, because it is quite confusing.

ICD-9-CM diagnosis and procedure codes are effective at the start of the Fiscal Year, which is 10/1 of each year. CPT/HCPCS procedure codes are updated yearly, and the new code set becomes effective at the start of the Calendar Year, which is 1/1 of each year. The Inpatient Prospective Payment System starts at the FY, on 10/1. Most other payment systems start at the CY, on 1/1.

Code sets and Payment Systems

AMA can issues an annual CPT update in the fall of each year effective January 1. They also issue an update to become effective July 1 CMS/Medicare does not accept all CPT codes. To see if Medicare accepts a CPT code, you must refer to any of a number of fee schedules. This means that a code issued by AMA may not become effective under Medicare immediately, or ever. CMS/Medicare issues an annual HCPCS update in teh fall of each year effective January 1. (HCPCS codes are procedure/service codes CMS creates to supplement the CPT codeset). CMS also issues updates throughout the year, with varying effective dates.

There are a number of fee schedules and Medicare edit systems with varying update schedules and effective dates which utilize HCPCS/CPT codes:

Physician Fee: Effective by Calendar Year and RVU files are updated quarterly. Outpatient PPS Addendum A& B for APC payment: Effective by Calendar Year and updated quarterly. Ambulatory Surgical Center Fee Schedule: Effective by Calendar Year and updated quarterly. Ambulance Fee Schedule: Effective by Calendar Year and updated yearly. Durable Medical Equipment Fee Schedule: Effective by Calendar Year and updated as necessary throughout the year. Clinical Laboratory Diagnostic Fee Schedule: Effectve by Calendar Year and updated as necessary thoughout the year. Integrated Outpatient Code Editor: Effective by Calendar Year and updated quarterly. Local Coverage Determinations/Medical Necessity: Revised everytime there is a logic or a coding logic change. These are updated and maintained by individual local contractors, but must follow CMS coding and coverage rules; Effective dates vary. National Coverage Determinations: Updated throughout the year, generally monthly; Effective dates vary. National Correct Coding Initiative (NCCI): Effective by Calendar Year and updated quarterly.

Regarding Grace Periods:

According to the Medicare Claims Processing Pub 100-04, Chapter 23:

The Health Insurance Portability and Accountability Act (HIPAA) requires that medical code sets must be date-of-service compliant. Since ICD-9-CM diagnosis codes are a medical code set, effective for dates of service on and after October 1, 2004, CMS will no longer provide a 90-day grace period for providers to use in billing discontinued ICD-9-CM diagnosis codes on Medicare claims. The updated ICD-9-CM codes are published in the Federal Register in April/May of each year as part of the Proposed Changes to the Hospital Inpatient Prospective Payment Systems in table 6 and effective each October 1.

And

The Health Insurance Portability and Accountability Act (HIPAA) requires that medical code sets must be date of service compliant. Since HCPCS is a medical code set, effective January 1, 2005, CMS will no longer provide a 90-day grace period for providers to use in billing discontinued HCPCS codes. The elimination of the grace period applies to the annual HCPCS update and to any mid-year coding changes. Any codes discontinued mid-year will no longer have a 90-day grace period. 

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October 3, 2008

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