Updated on: March 14, 2016

Champion your ICD-10 Strategy Regardless of Compliance Date

Original story posted on: March 9, 2015

Unless you have been in a coma (that’s ICD-10-CM code R40.2), you know that the deadline for the United States to begin using ICD-10 –CM for diagnosis coding and ICD-10-PCS for inpatient hospital procedure coding is set at Oct. 1, 2015. However, the implementation of ICD-10 has been subject to a series of previous delays: the current date is the product of yet another year-long delay from the previous 2014 deadline, which also was the result of a previous delay. In January 2009, the date was pushed back by two years to Oct. 1, 2013 rather than a prior proposal of Oct. 1, 2011. 


On Feb. 11, 2015, experts testified in Washington, D.C. that most healthcare providers are ready for ICD-10 coding to take effect on Oct. 1, 2015. Seven healthcare industry professionals, representing vendors, health insurance plans, physicians, and health information management experts, testified before the U.S. House of Representatives Energy and Commerce Committee's Subcommittee on Health regarding whether ICD-10 should be a go or a no-go.

Without question, we should move forward with the Oct. 1 deadline. There is no crystal ball, however, that will give us the answer to the million-dollar question: “Will ICD-10 be required on Oct. 1, 2015?” The best we can do is to accept the ICD-10-CM/PCS compliance date with the understanding that it is a 50|50 proposition. We simply do not know for sure. Based on our experience, a further delay is possible, so we must stay positive and plan for implementation as though there was not a doubt in our minds.

Famed playwright and author George Bernard Shaw once said that "people are always blaming their circumstances for what they are. I don't believe in circumstances. The people who get on in this world are the people who get up and look for the circumstances they want, and if they can't find them, make them." Knowing that we cannot predict the future, we must look at this circumstance the way we want it to work out and plan for ICD-10 compliance this year.

Regardless of the compliance date, all providers must brace for change, reexamine their organizational readiness, and correct their course as needed. It is important to stay positive and view this as an opportunity to take a moment to step back and assess your ICD-10 transition strategy. Consider the following: Does it address physician-generated clinical documentation, your clinical documentation improvement program, and coding compliance processes and solutions (including a defined core clinical documentation record set for coding compliance)?

At a minimum, your organization should review the following:

Clinical Documentation Integrity

This requires a focus on good clinical documentation, which can only be achieved with an organization-wide effort. Physician champions play a critical role in physician-to-physician education, and clinical documentation improvement (CDI) physician advisors act as a liaison between the CDI professional, health information management (HIM), and the hospital’s medical staff in order to facilitate accurate coding, diagnosis-related group (DRG) assignment, and representation of severity, acuity, and risk of mortality.

The integrity of the clinical documentation directly impacts accurate code assignment, billing, and payment timing. 2015 is the time for you to reevaluate the detail and quality of your medical record documentation and to implement and monitor documentation improvement strategies. There is an opportunity to not only continue to collaborate with physicians, but to expand your reach to the medical staff by providing CDI training to your providers. 

Your coding and compliance processes are dependent on effective clinical documentation and CDI processes. Coding solutions are typically very labor-intensive, and the onslaught of new ICD-10 codes and incomplete physician documentation could make it very challenging for your coding team. Is the current state of your clinical documentation and associated coding processes designed to meet the needs demanded by regulatory compliance? 

Additionally, as part of your coding compliance plan, create a unique “core clinical documentation set for coding compliance,”  that consists of key source documents or core designated record sets for coding – which are to be used by your coding professionals.

Leveraging the Right Technology for the Best Results

From coders to clinical documentation specialists, HIM teams are working smarter to maximize their time and streamline workflows. Using technology such as clinical language understanding (CLU) to help convert valuable unstructured data documented by physicians in medical records into meaningful and actionable information (and to find and attach appropriate billing codes) enables organizations to analyze important data from the beginning of the patient encounter through post-discharge and identify new ways of improving care. But making this change and leveraging technology require the coordinated efforts of properly trained people to implement and manage these improvements.

Truly understanding how technology can impact and influence employees and an organization will lead to better implementation plans that can improve patient care, streamline workflows, and drive profitability. See where you have opportunities to leverage your organization’s investment in an electronic health record (EHR) system. An essential component is reviewing workflows and redesigning processes with the addition of automated solutions and technology, and utilizing and enhancing EHR templates designed to capture co-morbid conditions and severity of illness, when appropriate. 2015 is your time to evaluate your organizational readiness for assistive technologies such as computer-assisted physician documentation (CAPD), computer-assisted CDI (CA CDI), and computer-assisted coding (CAC).

A few more steps to consider include:

Promote a culture for achieving excellence: Total quality management (TQM), continuous quality improvement (CQI), quality improvement (QI), or any other name you want to call it, is all about creating a culture that drives staff to achieve excellence in all processes and programs.

Among the most widely used tools for continuous improvement is a four-step quality model — the plan-do-check-act (PDCA) cycle, also known as the Deming Cycle or Shewhart Cycle:

Plan: Identify an opportunity and plan for change.

Do: Implement the change on a small scale.

Check: Use data to analyze the results of the change and determine whether it made a difference.

Act: If the change was successful, implement it on a wider scale and continuously assess your results. If the change did not work, begin the cycle again.

  • Start with a review of your original ICD-10 readiness assessment: It is important to build quality improvement into your processes. Self-evaluation is a critical success factor to accomplishing your goals, so be sure to plan, do, check, and act, as well as reevaluate the success of your multi­-disciplinary steering committee’s progress on the transition plan to oversee implementation processes (and to provide oversight of the entire implementation timeline).

  • Aggressively manage the progress of your internal ICD-10 transition road map and project plan: Review the project plan and validate that everyone is on target/schedule. Identify key tasks and objectives and assign to appropriate departments for follow-up. Based on the target dates for your deliverables, you may need to reprioritize concurrent projects, both related and unrelated to ICD­10-­CM/PCS, to ensure that timelines are met.
  • Expand CDI to address ambulatory care:Does your organization have an outpatient clinical documentation improvement (CDI) program? As the industry continues to see a dramatic increase in outpatient volume and outpatient claim denials, initiating an outpatient CDI program is necessary to ensure that the right information is being accurately captured in a timely fashion, particularly since these patients leave immediately after their visit. This is a perfect example of an important initiative for you to undertake regardless of the ICD-10 compliance date.

  • Know your own data: We hear everyone talking about big data and the importance of data analytics, but what does that mean to you? Identify major areas of change associated with the switch from ICD-9-CM to ICD-10-CM/PCS that impact data comparison and reporting for both internally and externally reported data. Determine the impact of the transition on longitudinal data analysis and consider that your legacy data will require conversion. Evaluate potential DRG shifts and case mix index changes. Actively establish correspondence with payors concerning possible revisions in reimbursement schedules and policies, paying careful attention to conversion policies, and be sure to analyze the impact on reimbursement due to improved clinical documentation.

The only other “delay prone” national initiative I can think of that is as unfortunate on a global level as the ICD-10 delay is the long and sad story of the adoption of the metric system (or lack thereof) in the United States. The delay strategy is simple and even quite elegant. Those in control do everything to delay the event as long as possible. Just like a legal defense strategy, the longer it takes, the more chances there are that the interested parties involved will simply give up. The ICD-10 delay strategy has been brilliant for those who fear ICD-10; however, there should be nothing to fear. ICD-10 is an important global health initiative, and it is important that we implement it so we can better track population health trends. 

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.
Bonnie S. Cassidy, MPA, RHIA, FAHIMA, FHIMSS

Bonnie Cassidy is a leading Health Information Management executive advisor, focusing her efforts on raising awareness and advancing HIM expertise in clinical documentation integrity and risk adjusted reimbursement.  As the president of Cassidy & Associates, Bonnie provides advisory services to healthcare organizations.  She is currently focusing her consulting in areas of organizational learning, leadership development and revenue integrity.

Cassidy was the 2011 President of AHIMA/Chair of the AHIMA Board of Directors, and the 2015 Chair of the Board of Directors for The Commission on Accreditation for Health Informatics and Information Management (CAHIIM).  Bonnie is a Fellow of AHIMA, an AHIMA Academy ICD-10-CM/PCS Certificate Holder, is a Fellow of HIMSS, an advanced member of HFMA and is serving on the 2019 AHIMA Nominating Committee.