April 7, 2014

Another ICD-10 Delay – Now You Have the Time Needed to Maximize Your Preparedness and Perform Due Diligence and Testing

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Readiness surveys conducted during the past two years showed that the industry was so challenged with competing initiatives that there simply was not enough time to complete all of the necessary preparations for ICD-10. The magnitude of the project was simply overwhelming. In fact, it was so difficult to engage providers during the March CMS Test week that clearinghouses rejoiced when we had 5,000 or 10,000 claims to submit. So while some complain and speculate about what this new delay will cost, I look at the opportunities this affords the industry for appropriate due diligence and the chance for comprehensive testing to flush out any questions or potential failures.

As we know, all covered entities must transition to ICD-10 at the same time to ensure a smooth transition. Failure of any one industry segment to achieve compliance with ICD-10 would negatively impact all other industry segments and result in rejected claims and provider payment delays. The change in the compliance date for ICD-10 will give providers and other covered entities more time to prepare and fully test their systems.

No matter where you are in your transition activities, you now have an opportunity to properly plan the rest of your journey toward ICD-10 compliance. As you no doubt already have experienced, the ICD-10 transition affects every part of your healthcare business and activities. Just the number of systems and software involved is mind-boggling. Activities ranging from the registration process to transition timelines for obtaining ICD-10 codes for referrals stymied some, as payors took a different approach and had their own requirements for submissions involving ICD-10 codes. Who envisioned that such a simple process would become so convoluted?

With the delay, though, will come future impacts of competing elements such as the unique health plan identifier (HPID) and other entity identifier (OEID) – but let’s not address these elements now. Just keep these and other future requirements in mind as you move forward and modify your objectives and timelines.

The Centers for Medicare & Medicaid Services (CMS) previously had indicated that 2014 is “the year of ICD-10,” and that is true now as it was two weeks ago. In many cases providers already have taken the opportunity to simplify – systems, software, processes, departments, and contracts. We all wondered when we were going to achieve administrative simplification; I think we now have the picture. Through some changes that have already occurred, providers are demonstrating efficiencies and increasing revenues they once thought impossible.

Let’s discuss more about opportunities you now have thanks to the delay.

The delay offers industry partners additional time to prepare and test their systems to ensure a smooth and integrated transition to ICD-10. Activities can be completed for those awaiting system upgrades necessary for ICD-10, rather than implementing risk or contingency plans. Momentum should continue. Trading partners should take this time to evaluate and escalate their activities, making sure to keep government and commercial payors, vendors, providers, and other trading partners in the mix.

The following metrics depend on what you have accomplished to date to a large degree, but some key areas to consider include the following:

  • Technology, people, processes, claims, and reimbursements

  • Electronic health record system upgrades

  • Financial/revenue – complete historical analysis, future projections

  • Predictive analysis of risk diagnoses and the adoption of clinical steps to reduce impacts

  • Payor contract review/negotiations

  • Further calculations of revenue impact

  • Consolidated data integration – Systems, software, and peripherals

Also ensure that implemented system/software upgrades are not tied to the Oct. 1, 2014 date, and that those existing system capabilities will not be impacted. If you cannot continue to use ICD-9-driven edits, tables, and elements, you must contact your vendors immediately to schedule patches or revisions to accommodate.

If your vendor’s systems cannot be reversed to continue the use of ICD-9, system upgrades may have to be delayed, but keep in mind the timing and implementation of the upgrades. You do not want to be in a similar situation of potentially not meeting the compliance date.

Additional items to consider include the following:

  • Integrated testing of updated or new software into a new environment

  • Clinical documentation improvement

  • Ensured compliance with ICD-9 codes

  • Projected ICD-10 codes, plus DRG shifts associated with payors’ contractual changes

  • Analysis of use of computer-assisted coding tools in conjunction with ICD-10

  • Adjusted timetables for coder training – lengthen the timespan of dual-coding initiatives

  • Training initiatives targeting your most-impacted specialty with ICD-10 codes (orthopedics, OB, etc.)

  • Plans for “what-ifs”

About the Author

Mary Hyland is vice president of industry affairs for the SSI Group, Inc. Ms. Hyland joined SSI in 2001 and currently oversees HIPAA regulatory and privacy initiatives and has more than 30 years of experience in the healthcare industry. Mary maintains leadership roles in the healthcare industry serving on the boards of the Cooperative Exchange (a consortium of healthcare clearinghouses) and currently serves as vice president. She also served on the boards of the Workgroup for Electronic Data Interchange (WEDI), the Association for Electronic Health Care Transactions (AFECHT), and the Medical Banking Project (MB Project).

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