September 25, 2012

An ICD-10 Readiness Plan for the Human Resources Department

By

The Centers for Medicare & Medicaid Services (CMS) has announced that Oct. 1, 2014 is the official, albeit delayed, implementation date for ICD-10-CM and ICD-10-PCS. Some healthcare providers didn’t stop their ICD-10 implementation plans back in February, when CMS first announced that there would be a delay – but whether your facility stopped, slowed down, or didn’t miss a beat, there is much work to be done.

Human resources (HR) is one of the many areas where there is a major workload ahead. This department plays a vital role in the retention and recruitment of coding specialists and other key players involved in ICD-10 implementation. One way to ensure that HR can contribute to the successful implementation of ICD-10 is to assess its readiness. An ICD-10- readiness assessment consists of tasks and/or questions used to identify a department’s strengths and opportunities for improvement.

Before distributing an assessment, each facility should designate someone to train HR staffers who will be responsible for completing the assessment in order to ensure that they understand how to use the proper tools.

A sample HR department ICD-10 readiness assessment is provided below.

ICD-10 Readiness Goal: Identify staff members who need ICD-10 competency training.

Rationale: Many hospital staff members, with and without coding-related jobs or positions, will need to be trained in ICD-10-CM and ICD-10-PCS coding and/or documentation.

HR Task: Use a spreadsheet to document the names, titles and departments of all staffers who need to undergo (re)training in medical terminology, anatomy and physiology, pathophysiology, pharmacology, clinical documentation, ICD-10-CM coding, and/or ICD-10-PCS coding. ICD-10 Action Plan Item: Use the completed spreadsheet to monitor and track staff training status from start to finish.

  • Biomedicine (including medical terminology, anatomy and physiology, pathophysiology, and pharmacology);
  • ICD-10-CM coding (basic, intermediate, advanced);
  • ICD-10-PCS coding (basic, intermediate, advanced);
  • ICD-10-CM documentation; and
  • ICD-10-PCS documentation.

ICD-10 Readiness Goal: Assess the legal impact of ICD-10 on affected staff.

Rationale: There may be legal ramifications to consider when establishing sanctions and rewards associated with staff participation in ICD-10-related training. HR Task: Identify staff, such as coding specialists, who need to sign one of the following legal documents, which should be prepared by the legal department:

  • Facility-paid ICD-10 training agreement: The employee agrees to receive facility-paid ICD-10-CM/PCS coding training and will remain employed at the facility for at least 24 months after Oct. 1, 2014. Consider including language specifying a penalty, such as, if the employee resigns before the 24 months, he or she must reimburse the facility $5,000.
  • Employee-paid ICD-10 training agreement: The employee declines the facility-paid ICD-10-CM/PCS coding training and understands that he or she is responsible for obtaining comprehensive ICD-10-CM/PCS coding training no later than Dec. 31, 2013. The facility will test the employee on his or her ICD-10-CM/PCS coding skills shortly after Jan. 1, 2014. The employee understands that he or she is expected to comply fully with the facility’s ICD-10-CM/PCS coding accuracy and productivity standards that will go into effect on Oct. 1, 2014.

Work with the legal department to assess the impact of ICD-10 implementation on the following:

  • Union/organized labor positions;
  • Staff who will retire before Jan. 1, 2015 (for instance, can the organization exclude those staff from the training in order to spare the facility unnecessary training expenses?)
  • Staff that struggle with ICD-10 comprehension even after additional training has taken place.

ICD-10 Action Plan Item: Work with the hospital’s legal advisor to ensure that copies of all fully executed ICD-10 training agreements are placed in each applicable employee’s personnel file.

 


 

ICD-10 Readiness Goal: Coordinate a financial bonus-based incentive plan for ICD-10 training completion.

Rationale: A bonus may be an excellent incentive for staff to remain at the hospital upon completion of their ICD-10 training.

HR Task: Research the hospital’s use of financial bonus-based incentive plans in the past for circumstances similar to ICD-10 training. Obtain a copy of the prior incentive plan(s).

ICD-10 Action Plan Item: Coordinate the implementation of a financial bonus-based incentive plan for designated staff authorized to receive a bonus upon successful completion of the facility-paid ICD-10-CM/PCS coding training. For example, the health information management (HIM) director may agree to such a plan for all coding specialists.

ICD-10 Readiness Goal: Revise job descriptions.

Rationale: Job descriptions that reference ICD-9-CM must be revised to reflect ICD-10-CM and/or ICD-10-PCS before Oct. 1, 2014. HR Task: Gather hard copies or electronic copies of all job descriptions that reference ICD-9-CM-related responsibilities (including non-coding job descriptions).

ICD-10 Action Plan Item: Mandate and coordinate each department manager’s review and updating of all job descriptions that require medical and/or procedural coding. Managers should replace the level of skills required for the ICD-9-CM coding system with the updated skills required for the ICD-10-CM and ICD-10-PCS coding systems.

ICD-10 Readiness Goal: Reassess pay grades and salaries.

Rationale: ICD-10-CM/PCS coding skills are and will continue to be in high demand in the job market. It is imperative that the hospital’s coding salaries remain competitive within the market.

HR Task: Research and document the pay grades and salaries nationwide for positions that involve ICD-10 coding (ICD-10 subject matter experts, ICD-10 coders, etc.).

ICD-10 Action Plan Item: Reassess the pay grades and salaries for all positions involving ICD-10 medical and/or procedural coding skills. If applicable, comply with agreements in place for union/organized labor jobs or positions. Justification for coding position salary increases include:

  • Increased extraction and analysis of clinical documentation needed for ICD-10-CM diagnosis coding.
  • Increased complexity of procedural coding under ICD-10-PCS.
  • Application of new and expanded coding guidelines for both ICD-10-CM and ICD-10-PCS.

ICD-10 Readiness Goal: Ensure that personnel records reflect proof of ICD-10 assessment/competency.

Rationale: The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) compliance guidelines for hospitals require that hospitals document employee completion of any required training.

HR Task: Write a policy and a procedure for the collection of all documents that prove staffers have completed internal and/or external ICD-10-related training.

ICD-10 Action Plan Item: Work with department managers to ensure that the following documents are placed in the personnel records of all staff who will perform ICD-10 coding for the facility:

  • Certificates of completion for in-house and/or external ICD-10 training; and
  • Certificates of completion for in-house and/or external biomedicine sciences training (such as medical terminology, anatomy and physiology, pathophysiology, and pharmacology).


ICD-10 Readiness Goal: Fund scholarships to attract coding specialists:.

Rationale: The anticipated decrease in coding productivity under ICD-10 may require some hospitals to hire additional coding specialists. In order to attract the additional coding specialists needed to handle the increased workload associated with ICD-10 implementation and beyond, consider funding scholarships for students to attend a local coding program with an employment stipulation (at your facility) upon graduation.

HR Task: Research the hospital’s past or current experiences funding scholarships to attract professionals in any profession. Obtain a copy of the scholarship funding process/requirements.

ICD-10 Action Plan Item: Fund one or more scholarships for coding students (if feasible), with the caveat that the student must come work at the hospital for a specified period of time.

After the ICD-10 readiness assessment is completed and submitted, the HR department should receive feedback about its completed assessment from the ICD-10 steering committee.

Completing this assessment will enable hospital leadership to track and report on the progress of ICD-10 implementation for the HR department.

About the Author

Lolita M. Jones, RHIA, CCS, is the principal of Lolita M. Jones Consulting Services (LMJCS), founded in October 1998 in Fort Washington, MD.  Ms. Jones has over 25 years of experience in coding and consulting. She started preparing for the implementation of ICD-10-CM/PCS by going back to school. On Sept. 12, 2010, Ms. Jones became an AHIMA-approved ICD-10-CM/PCS trainer.

Contact the Author

To comment on this article please go to

References:

“ICD-10 Preparation Checklist,” February 2009, ICD-TEN newsletter, Sue Bowman, RHIA, CCS, and Ann Zeisset, RHIT, CCS, CCS-P, AHIMA, Chicago.

ICD-10 Summit, April 12, 2010, Washington, D.C.: “Catch a Ride on the 5010/ICD-10 Jet Plane! Before It’s Too Late,” Bernice von Saleski, RHIA,MAS, corporate coding director, Partners Healthcare Systems, Boston.

Disclaimer: Every reasonable effort was made to ensure the accuracy of this information at the time it was published. However, due to the nature of industry changes over time we cannot guarantee its validity after the year it was published.
Lolita M. Jones, RHIA, CCS

Lolita M. Jones, RHIA, CCS, is the principal of Lolita M. Jones Consulting Services (LMJCS), founded in October 1998 in Fort Washington, MD. Ms. Jones has over 25 years of experience in coding and consulting. She started preparing for the implementation of ICD-10-CM/PCS by going back to school. On September 12, 2010, Ms. Jones became an AHIMA-approved ICD-10-CM/PCS trainer.