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ACP offers a number of resources to help members make sense of the MOC requirements and earn points.
Understanding MOC Requirements
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Q: Am I required to report external causes of
A: External Cause Codes
Just as with ICD-9-CM, there is no national requirement for
mandatory ICD-10-CM external cause code reporting. Unless a
provider is subject to a state-based external cause code reporting
mandate or these codes are required by a particular payer,
reporting of ICD-10-CM codes in Chapter 20, External Causes of
Morbidity, is not required. If a provider has not been reporting
ICD-9-CM external cause codes, the provider will not be required to
report ICD-10-CM codes in Chapter 20, unless a new state or
payer-based requirement regarding the reporting of these codes is
instituted. Such a requirement would be independent of ICD-10-CM
implementation. In the absence of a mandatory reporting
requirement, providers are encouraged to voluntarily report
external cause codes, as they provide valuable data for injury
research and evaluation of injury prevention strategies.
Q: I don't always know the diagnosis until testing has
been completed. Will unspecified codes be denied?
A: Sign/Symptom/Unspecified Codes
In both ICD-9-CM and ICD-10-CM, sign/symptom and unspecified
codes have acceptable, even necessary, uses. While specific
diagnosis codes should be reported when they are supported by the
available medical record documentation and clinical knowledge of
the patients health condition, there are instances when
signs/symptoms or unspecified codes are the best choices for
accurately reflecting the healthcare encounter. Each healthcare
encounter should be coded to the level of certainty known for that
If a definitive diagnosis has not been established by the end of
the encounter, it is appropriate to report codes for sign(s) and/or
symptom(s) in lieu of a definitive diagnosis. When sufficient
clinical information isnt known or available about a particular
health condition to assign a more specific code, it is acceptable
to report the appropriate unspecified code (e.g., a diagnosis of
pneumonia has been determined, but not the specific type). In fact,
unspecified codes should be reported when they are the codes that
most accurately reflects what is known about the patients condition
at the time of that particular encounter. It would be inappropriate
to select a specific code that is not supported by the medical
record documentation or conduct medically unnecessary diagnostic
testing in order to determine a more specific code.
Q: How do I report ICD-10 codes on claims when the dates
of service span from prior to 10/1/2015 to on or after
A: Many payers are requiring claims with dates
of service that span the October 1, 2015 implementation date to be
split so that the services prior to 10/1/2015 are billed separately
and utilize ICD-9 codes; services on and after 10/1/2015 are billed
separately and utilize ICD-10 codes.
Check specific payer guidelines for processing claims for
services that span the 10/1/2015 ICD-10 transition date.
Q: If I submit or process a transaction with an ICD-9
code for a date of service after October 1, 2015, am I HIPAA
A: The date of service determines the compliant
code format to be used in a claim regardless of the date the claim
is filed or submitted. Physicians will submit claims after October
1, 2015 with ICD-9 codes when the services were performed prior to
October 1, 2015. Payers will process claims if received after
October 1, 2015 with ICD-9 codes when the services were performed
prior to October 1, 2015. This situation is HIPAA compliant.
Q: How long after the October 1, 2015 ICD-10 compliance
date must I continue to report and/or process ICD-9
A: Each payer determines their late filing
requirements for standard transactions and ICD-10 does not require
a change to these requirements. These deadline requirements vary
among plans. Contact your payer for the current information
regarding late filing for claims.