April 4, 1997
Medical/Clinical Coding and Classification Issues in the Implementation of Administrative Simplification Provision of P.L. 104-191
The American Optometric Association appreciates the opportunity to comment upon the medical and clinical coding issues in connection with the requirements of the Health Insurance Portability and Accountability Act of 1996 (P.L. No. 104-191). We would like to address the questions posed by the Subcommittee as follows:
The profession of optometry currently uses the American Medical Association's Current Procedural Terminology (CPT), and the Health Care Financing Administration Procedural Coding System (HCPCS), to report health care services. It uses the International Classification of Diseases, Ninth Edition, Clinical Modification (ICD-9-CM) to report the diagnosis of diseases, injuries, impairments, other health related problems and their manifestations.
Additionally, optometry uses HCPCS Level 2 and 3 codes to report the prescription of materials when indicated and accepted by the carrier. In many instances, carrier-specific coding systems are used to report materials services.
For payment purposes, eye health care services provided by doctors of optometry are currently reported on the HCFA 1500 form. Vision care services are reported using a variety of insurance carrier-specific forms and formats, including the AOA/HIAA Standard Vision Care Reporting Form and Vision Service Plan (VSP) Benefit Form.
Given the time frames for HIPAA, the AOA would consider it reasonable to remain with the CPT and ICD-9-CM coding systems as the initial standards for administrative transactions.
The AOA supports the adoption of single coding and classification systems for reporting services, diagnoses and materials. It would be beneficial if all these coding and classification systems were in the public domain. It would urge the development and maintenance of standard guidelines for coding and documentation of procedures and diagnoses to be used by both public and private health care programs. Discretionary carrier reinterpretation and redefinition of codes should not be allowed. Such reinterpretation has caused major confusion for optometrists and their staffs as they strive to accurately report their services for payment.
The AOA cannot offer an informed opinion on either the clinical modification of ICD-10-CM nor ICD-10-PCS since, at this time, it has not had the opportunity to review either coding system.
We believe it would benefit the development process for these coding systems if all health care providers who would potentially use these systems to be included in the review and field testing processes. AOA would welcome participation in the process at the earliest possible opportunity.
Administrative simplification can only be realized if all parties have open, equal and balanced access to all aspects of the process during the development period.
The AOA supports the acceptance of single coding and classification systems for reporting services, diagnoses and materials provided for both the ambulatory and the inpatient sectors. It would be preferable if all these coding and classification systems were in the public domain to ensure meaningful participation in the development and education process.
Regarding the implementation and maintenance of any new coding systems and reporting mechanisms and the training implicit in that implementation, the AOA feels that both implementation and training will have to be a shared experience in terms of time, training and cost for all groups that use the systems.
As we have stated, it would be preferable to have all coding systems in the public domain. In order to ensure compliance, all health care professions must be permitted to publish educational and instructional materials developed by each discipline, stringently based on standard guidelines that educate the practitioners with terms and examples that are easily understood within the profession. Such efforts could be hindered by the adoption of proprietary coding systems.
It has taken the profession of optometry many years to get doctors and staff to a workable level of sophistication with current coding systems. This educational process has been achieved by a cooperative effort of national and state optometric organizations. The cost of educating optometrists in the use of new coding systems would be significant. If our experience is any guide, any new coding system will be met with trepidation and resistance by provider communities. However, if new coding systems improve the accuracy of reporting and the ease of administrative and reimbursement transactions, the market would no doubt accept the new systems.
We would strongly recommend that all educational guidelines for coding, reporting and payment purposes be available at the same time that new systems are introduced. The piecemeal development, adoption and distribution of coding guidelines results in inaccurate reporting of services and an unnecessary burden of constant reeducation of users.
The AOA has no major concerns with the process as outlined in its Charge. We strongly urge the Implementation Team to allow open access to the process, where appropriate. Any standards and coding system changes should be disseminated to all interested parties at the same time so that informed responses can be provided.
There is one additional coding complication for eye care services that the AOA would like to bring to the Committee's attention. The coding systems used by doctors of optometry to identify specific ophthalmic materials supplied to patients are not necessarily the same coding systems used by ophthalmic manufacturers and optical laboratories to identify their products. With the onset of electronic transactions, the AOA would urge the Committee to investigate mechanisms by which ophthalmic materials could be uniformly identified and tracked through the various stages from manufacture, through processing of prescriptions to supply to patients.
If the Committee requires further clarification or comment from the American Optometric Association, please do not hesitate to contact us.
The AOA looks forward to continued input as this project develops to ensure that the data needs of optometry are clearly defined in the system.
CONTACTS: Douglas C. Morrow, OD
Chairman, Coding Subcommittee
Eye
Care Benefits Center
American Optometric Association
Telephone:
219-925-1916
Fax: 219-925-5000
Renee Dworakowski-Howe
Manager
Eye Care Benefits Center
American
Optometric Association
1505 Prince Street, Suite 300
Alexandria,
Virginia 22314
Telephone: 703-739-9200
Fax: 703-739-9497
E-mail:
rdhoweaoa@aol.com
ecbc\codes\497cmnt.doc