Updated on: March 16, 2016

CMS’s National Provider Call Focuses on AHIMA’s Preparation and Planning Checklist

Original story posted on: November 28, 2011

First things first: The Centers for Medicare & Medicaid Services have no intention of changing the October 1, 2013, implementation of the ICD-10-CM system.

That’s the official statement given by one of the speakers during the question-and-answer period of the November 17 ICD-10 Implementation Strategies and Planning National Provider Call—in response to a question one attendee asked and many callers wondered about: What was CMS’s response to the recently issued statement from the American Medical Association that it would “work vigorously to stop implementation of ICD-10”? (For the AMA’s statement, go to http://www.ama-assn.org/ama/pub/news/news/2011-11-15-ama-adopts-new-policies.page.)


In CMS’s reply, read by Pat Brooks, RHIA, senior technical advisor of the agency’s hospital and ambulatory policy group, it also emphasized that healthcare providers have had ample time to begin the transition from ICD-9-CM to ICD-10-CM diagnoses and procedure codes.

Moving Forward

For anyone who has been keeping up with the flurry of information about the transition to ICD-10, this call proved to be part review of various administrative details. The real meat of the call related to the highlights of the ICD-10-CM/PCS Transition: Planning and Preparation Checklist, which the American Health information Management Association (AHIMA) initially published in 2007 and updated this year.

Pat Brooks launched the provider call by listing the agency’s implementation deadlines and billing requirements. In addition to confirming the start date of October 1, 2013, she clarified that, although all healthcare providers must use ICD-10-CM diagnosis codes, ICD-10-PCS (procedures) will be used only for hospital claims for inpatient hospital procedures.  ICD-10-PCS will not be used on physician claims, even for inpatient visits.  CPT and HCPCS level II codes will continue to be used for physician and ambulatory services.

Brooks also outlined the following billing guidelines related to code use.

  • Claims for inpatient discharges occurring on and after October 1, 2013, must include ICD-10 diagnosis and procedure codes.  ICD-9-CM codes will not be accepted on and after that date, just as ICD-10 won’t be accepted for services prior to October 1, 2013.
  • On October 1, 2011—just two months ago--the last, regular annual updates to both ICD-9 and ICD-10 took effect. For fiscal year (FY) 2013, which begins October 1, 2012, ICD-9 and ICD-10 codes will be updated only to include new technology and diseases. On October 1, 2013 (FY 2014), updates will be made to ICD-10 only to capture new technology and diseases.
  • Regular annual updates to ICD-10 will begin on October 1, 2014 (for FY 2015).

Rationale for Planning

The benefits of the new ICD-10 system far outweigh the challenges ahead. That’s one of the messages that the American Hospital Association (AHA) and AHIMA want to send to providers who are at the early, and intimidating, stages of the conversion.

During a joint presentation, AHIMA’s director of coding and compliance, Sue Bowman, RHIA, CCS, and the AHA’s director of coding and classification, Nelly Leon-Chisen, RHIA, covered general implementation planning and strategies. Bowman first gave the details of the benefits of the ICD-10-CM/PCS, which include (but aren’t limited to):

  • Better data for evaluating and improving quality of care;
  • More accurate payment, improved justification of medical necessity, and fewer erroneous and rejected claims;
  • Research opportunities, including code and clinical analyses; and
  • A tool to monitor organizational performance related to various areas, including administrative efficiencies, trend and cost analysis, resource and service utilization, and improved coding accuracy and productivity.



As far as challenges go, several overlapping timelines share first place. In addition to preparing for ICD-10, providers and vendors face several regulatory changes, starting with the implementation of version 5010 of the electronic claim form on January 1, 2012.  (Note, however, that CMS recently announced a three-month grace period to this deadline.) Other timelines to face relate to meaningful use of electronic health records (EHRs), health-reform initiatives, and HIPAA privacy changes.

Unfortunately, there are consequences of being poorly prepared for ICD-10 implementation, including increased claims’ rejections and denials, improper payments, coding backlogs, and decision-making based on inaccurate data. Avoiding the consequences is easy, said the speakers and their slides: “Don’t delay getting started! Begin if you haven’t already done so! “

The slides shown during the presentations of Bowman and Leon-Chisen echo an oft-heard message: “Early initiation of the planning process, thorough preparation, adequate education, and proper testing will result in smoother transition and earlier realization of benefits.”

Planning and Preparation

Providers who are still wondering where to start need look no further. One of the most comprehensive to-do lists can be found at AHIMA’s web site: http://www.ahima.org/downloads/pdfs/resources/checklist.pdf . As explained by Bowman, AHIMA developed the checklist to guide all types of healthcare organizations in effectively planning and managing the ICD-10 implementation. According to the checklist, implementation includes four phases: impact assessment, preparation, go-live preparation, and post-implementation follow-up.

The proactive providers who have followed AHIMA’s checklist have already completed (during the second quarter of 2011, in fact) the impact assessment—the first phase—and are now entering the second phase of preparation.  According to AHIMA’s plan, these providers will be ready on October 1, 2013, for ICD-10, and will conduct the post-implementation follow-up one year later.

Unfortunately, the above is not the case for most providers, and one of Bowman’s slides heeds a warning:  Delayed completion of the impact assessment will jeopardize the ability to complete all ICD-10 implementation tasks by the compliance date. Nonetheless, the speakers presented the steps that the latecomers must take toward implementation.

Time for Action

Assessing organizational readiness is the initial step of AHIMA’s first phase. This includes conducting a survey of all business areas and analyzing ICD-10’s impact on business processes. A systems’ audit also must be performed to ensure that hardware and software are compatible with the ICD-10 system; if not, they must be replaced or upgraded.

Be aware that there are numerous systems and applications that may be affected by the transition, including the following (and many others not listed):

  • Encoding software;
  • Billing systems;
  • Practice-management systems;
  • Groupers;
  • Clinical and decision-support systems;
  • Case-mix systems;
  • Financial; and
  • Medical necessity software.

Next up is a coding-gap analysis to determine coders’ skills and knowledge of the biomedical sciences (especially anatomy and physiology, and pathophysiology), medical terminology, and pharmacology. Analysis of various types of medical records is equally important to determine whether documentation supports ICD-10’s level of detail. If it does not, providers must consider whether to implement documentation-improvement strategies and physician education.

The last, but not least, to-do items in phase one of AHIMA’s checklist involve training, budgeting and ensuring business-associate readiness. Who will need to learn ICD-10, and what level of education do they need?  For example, coders will need the highest level of training followed closely by clinicians while registration and billing staff will need a lower intensity of ICD-10 knowledge.

Developing a budget for the ICD-10 transition and its associated costs involves many levels, including modifying hardware and software; training staff; hiring temporary coders; consulting services; and maintaining dual code sets. Finding out whether your business associates (systems’ vendors and payers) are ready must be addressed as well.

As providers proceed into the checklist’s phase two, they will be continuing and finalizing the tasks begun in the first phase. Added to these will be a focus on general equivalency mappings (GEMs), which CMS designed to help users navigate the “complexity of translating meaning from the contents of one code set [ICD-9] to the other code set [ICD-10].” The speakers described when GEMS should be used (to convert databases and compare data) to when they should not be used, such as:

  • When you have access to the medical record, text descriptions or clinical terms describing diagnoses and procedures;
  • When only a few codes are being converted; and
  • When you are coding medical records.

The Wrap-Up

Although the above presentation by Bowman and Leon-Chisen took up the bulk of the national provider call, it ended with two more brief presentations. Donna Pickett, RHIA, reviewed the National Committee on Vital and Health Statistics (NCVHS) June 17, 2011, meeting on provider and vendor readiness. Pickett, who is a medical systems administrator with the National Center for Health Statistics, summarized what she called “cross-cutting observations and recommendations” from the 26 individuals who testified at the meeting.

Overall, the testifiers, who represented all parts of the industry (including health plans, providers, vendors, etc.) expressed concern for both 5010 and ICD-10 industry readiness.  They also encouraged continued communications with the industry from CMS about system implementation preparations as well as early testing between trading partners.

A quick reminder about the billing and reporting guidelines for ICD-10, which can be found in MLN Matters article 7492 (at https://www.cms.gov/MLNMattersArticles/downloads/MM7492.pdf), wrapped up this provider call with representatives from the agency’s Provider Billing Group. Sara Shirey-Losso and Antoinette Johnson from CMS gave the key points of the memo and emphasized, again, compliance dates.

Where to Find More

All of the presentations were chock-full of web sites, but here are a few sure bets for more information.



Janis Oppelt

Janis keeps the wheel of words rolling for Panacea®'s publishing division. Her roles include researching, writing, and editing newsletters, special reports, and articles for RACMonitor.com and ICD10Monitor.com; coordinating the compliance question of the week; and contributing to the annual book-update process. She has 20 years of experience in topics related to Medicare regulations and compliance.