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[UCE]Re: ICD-9 proposed changes, your support is needed

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Dear Kippley and others,

I want to endorse Sheila St. 's previous responses to these

questions. They are all right on target.

I will add a few comments below.

With regard to who decides who (and what type of instruction and

its content) is eligible to be reimbursed, that is not a decision of

this government committee. The government ICD9 committee decides

what codes are available. It does not credential providers or

provide lists of acceptable qualifications.

and

others,

Some question that come to mind

immediately are the following.

1.

What sort of service providers will be included? If this is a

matter of ICD-9-CM codes, can such forms be filled out by providers

who are not doctors or part of a recognized medical staff? In

brief, will volunteer teachers of NFP who collect a fee for materials

and the course be able to fill out the paperwork so that the student

couple can seek health insurance reimbursement?

None of this is regulated or mandated by adding and ICD9 code.

ICD9 codes have a specific limited purpose- to broadly categorize

a service that is being provided.

ICD9 codes have nothing to do with assessing or documenting the

qualifications of a provider or a program of instruction, or what

appropriate reimbursement is or whether someone will be

reimbursed.

It is possible for anyone who provides a health service to fill

out a form for an insurance company, describe what was provided, and

use an ICD9 code. Whether they get reimbursed is up to the

insurance company.

ICD9 codes are used mostly by physicians, but they can be used by

anyone who provides a professional health service. Again,

whether they get reimbursed is up to the insurance company.

2.

What sort of instruction will be covered? Will instruction in

morality be covered? Will instruction in ecological

breastfeeding be covered?

None of this is regulated by either the current ICD9 codes or the

future proposed ICD9 code. It is up to the insurance company to

decide whether a service provided does in fact fit the definition of

" natural family planning. " We have proposed the 1982

WHO definition of natural family planning:

"Methods for planning and preventing pregnancy by observation

of the naturally occurring signs and symptoms of the fertile and

infertile phases of the menstrual cycle, with the avoidance of

intercourse during the fertile phase if pregnancy is to be avoided."

Hopefully this definition makes it into the documentation with

the new coding, should it be added. It would be helpful if some

of the letters of support that are sent to the government committee

emphasize the importance of this definition of NFP.

3. This appears to be an effort on

the part of Hilgers-trained physicians to get insurance companies to

pay for their services. To what extent have the leaders of this

effort worked with other providers to

" identify services offered by NFP providers and the options for

insurance reimbursement for instruction in

NFP " ?

While this was an Academy initiated effort (over many years),

specifically the Academy committee on Third Party reimbursement,

providers of other models (primarily physicians) were consulted and

provided feedback.

4.

Will there be any sort of requirement that reimbursable NFP

providers need to let their clients know that there are other

forms of NFP instruction, some of whch may be more complete and less

expensive?

Again, that is not the purpose of ICD9 codes. Perhaps it

would be helpful for those who are not familiar with the role of ICD9

codes to review some of the online documentation about them.

Here is a good starting point.

http://www.cdc.gov/nchs/about/otheract/icd9/abticd9.htm

5. Why

was there no mention of changes in the cervix in the slide description

of the Sympto-Thermal Method?

As someone who had primary responsibility for the slides, I will

note that the purpose of the presentation was to give a brief overview

of established NFP methods, and not specific details for any of the

methods.

6.

Will this coding enable contraceptively-oriented doctors to collect

funds by checking these codes even if all he says about NFP is a brief

and negative description with adjectives that make it appear out of

the reach of ordinary people?

If the doctor ultimately provides something other than NFP, he or

she would be much more likely to code under the family planning method

that was actually provided.

That a code might conceivably be misused by some does not

outweigh the good use to which it can be put.

7. If

this coding is approved, will it set a national standard that all

health insurance companies will have to

follow?

No, but it will open doors for insurance companies to recognize

NFP that are now closed.

8. If

so, who will set the dollar amounts to be reimbursed to the

client-patient? Or are the amounts to be paid directly to the

service provider?

How much may be paid and what reimbursement procedures may be put

in place is a result of negotiation between providers of service and

insurance companies. Having an ICD9 code will allow such

negotiations to take place.

Thanks for

addressing these questions.

F.

Kippley

NFP

International, Inc.

In summary, getting NFP codes into ICD9 is a prerequisite for

identifying qualifications, criteria, and procedures for

reimbursement, but it has nothing directly to do with qualifications,

certification, and reimbursement. The proposed new NFP

codes say nothing about specific NFP methods or service delivery

systems. All NFP methods and service delivery systems will

benefit from the increased medical recognition of NFP methods for

avoiding and achieving pregnancy that will come from having specific

procedure codes in these categories, whether or not they choose to

seek reimbursement from insurance companies.

I hope this helps to answer these questions.

Joe Stanford

--

______________________________

ph B. Stanford, MD, MSPH

University of Utah

Department of Family and Preventive Medicine

jstanford@...

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