Regulations adopted in October 2013 allow hospitals to bill Part B for inpatient cases that are internally reviewed and "self-denied" within one year of the date of service. But utilization review staff are unsure when to use the old condition code 44 process and when to opt for the new process using condition code W2. Operationalizing these rules can prove to be challenging, causing recoding, rebilling, and expensive slowdowns in the revenue cycle.

With the transition to ICD-10, some documentation issues have required the capture of new information while others involve updated, modified, and otherwise expanded documentation needs. As we gain experience with ICD-10 and more questions are answered, physicians, coding professionals, and other clinical staff must continue training in clinical documentation improvement (CDI) and ICD-10. Now comes the hard work: ensuring consistency and reliability of ICD-10 coded accounts and the analytics that will be the outcome of ICD-10 data.