Workers' Comp and ICD-10

With the recent delay in the ICD-10 transition, many payors, providers and vendors are forced to reassess their transition plans and timelines. While some may be breathing a sigh of relief many others have felt the frustration of the delay. Fortunately, the folks at ICD-10 Illustrated have found an avenue to provide comic relief to ICD-10’s victims.  Their illustrated book, Struck by Orca, brings the magic of ICD-10 to life through the creative works of artists all over the world. If ICD-10 ever has you on the verge of insanity (ICD-10 Code F22), it’s worth flipping through this gem.

All chuckles aside, it’s important to consider ICD-10’s implications on the world of workers’ compensation. Although a non-HIPAA covered entity, workers compensation is no exception. Increasingly, workers compensation carriers are indicating they too will shift to ICD-10 despite not being required to do so. While some carriers, such as Anthem Workers’ Compensation (AWC) and the Ohio Bureau of Workers Compensation, have confirmed their move to ICD-10, this in no way should be held as a promised standard. With such a vague picture of the future, I’d like to share some observations made while working with provider organizations during their implementation process.   


The importance of understanding your workers compensation carriers’ detailed transition plans cannot be overstated. If a workers compensation carrier will transition to ICD-10, will it transition by 10/1? Does the carrier have a testing strategy in place? Does the strategy test the technical processes and pricing and reimbursement structures? How closely does a technical test mirror production processes? What number and type of accounts would constitute a comprehensive pricing and reimbursement test? In my experience with testing with commercial payers, what constitutes a comprehensive test strategy is not necessarily consistent across payers nor does it always align with provider expectations. With an extra year to prepare, you can use this opportunity to better understand your carrier readiness plans and coordinate testing strategies.

Note: If you suffer from Z73.4 – Inadequate social skills, not elsewhere classified, this may not be a task that’s up your alley.

Don’t Assume. 

Of course you shouldn’t expect that you will be able to get detailed readiness plans from all workers compensation carriers. At the same time, you shouldn’t count on all carriers taking the same steps to prepare or that they will all even convert to ICD-10 by the transition date. With that in mind, your organization might consider potential scenarios that could unfold during the transition. For example, you may choose to submit your workers compensation claims under ICD-10 unless a carrier has explicitly stated they will not be converting. After receiving a few rejections or denials you identify a workers compensation plan that is not accepting ICD-10. You then need to update your practice management system to submit claims for that carrier under ICD-9 and ensure your denied claims are coded and resubmitted with the ICD-9 code set. 


Please also do not assume knitting or crocheting is as safe as it sounds. There’s an ICD-10 code for that!

Monitor Post-Live Progress.

Having readiness plans upfront implies a need for monitoring later on. While workers compensation may contribute to a relatively small percentage of your overall revenue, at this point, as you might’ve noticed, much of what’s been discussed can be applied to other payers and carriers. So with that I believe pre-defined post-live monitoring strategies a relevant point of discussion.

Before you can spot trends and identify issues, it is critical your organization has a solid understanding of the key metrics you’ll want to track during the transition and what the baselines are for the metrics under ICD-9. Example metrics might include average response time for a workers compensation claim or top denials by payer. Making an assumption that plans will directly tell you they are not ready or experiencing technical problems processing your ICD-10 claims would be a mistake. It is important that your organization proactively monitor against existing baselines and take appropriate action based on observed deviations. Early and consistent monitoring of your key metrics will allow you to act quickly in order to minimize impact to your revenue cycle.

Although you may still be coming to terms with the shock* of yet another delay, you can use this time as an opportunity to further minimize risk and impact. Certainly the future state for workers compensation is one of the bigger question marks; however, with strong communication, forward planning, and post-transition monitoring, you can reduce some of those risks during your transition.

*Know what else is shocking? Knowing that someone has been burned due to water skis, or at least that there’s an ICD-10 code for it.


Author: Monica Hurst is an ICD-10 specialist at the BlueTree Network

1 comment

  • Anita Archer

    Your ICD-10 card deck was mentioned by a prominent healthcare vendor during a conference that I attended. I followed up by visiting the website, & ordered some playing cards. My colleagues and I are so impressed with the quality and content that we have decided to order a number of the card decks for our clients. They make great conversation pieces and are a welcome aspect of humor about this ICD-10 beast! Nice work.

    Anita Archer
    Director, Regulatory & Compliance
    Hayes Management Consulting

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