Updated on: November 21, 2016

Closure at Last on a Long Journey - Maybe

Original story posted on: April 17, 2015

EDITOR’S NOTE – This is the second installment in a two-part series on industry reaction to the U.S. House of Representatives passage of the H.R. 2 bill, from which ICD-10 escaped unscathed.

For many ICD-10 stakeholders, the U.S. Senate’s passage of the Medicare reform bill last Tuesday was a fait accompli.

The heavy lifting had been lifted. Arms had been twisted. Hearings had been heard. Teeth were clenched. Fingers crossed. And there it was, like a newborn baby under parental scrutiny: H.R. 2.


Born March 26. No amendments. No pay cuts to physicians and no delay of ICD-10.

So when the Senate voted overwhelmingly, 92-8, for the $200billion Medicare reform package, it ended the loathsome “doc fix” and also foreclosed any hopes by some of another ICD-10 delay.

Passage of H.R. 2 could have been an exhaustive victory lap were it not for the fact that hospitals, health systems and physician practices, clearinghouses, and payors had been moving ahead doggedly (and, albeit, in some cases, disjointedly) to implement the long-awaited code set. Instead, passage of H.R. 2 arrived almost as an afterthought. The seventh inning stretch. A cup of coffee in the break room. Peeling off single-use rubber gloves.

In what now seems a postmortem, Talk Ten Tuesdays asked six major professional organizations for their reaction to passage of H.R. 2, and also to describe where they are with ICD-10 implementation initiatives. They appeared on the March 31 broadcast, a special 60-minute edition. Here are excerpts from members of three of those associations, plus two private industry representatives.


“While we are pleased with the progress not only with ICD-10 but also the SGR (sustainable growth rate), we need to keep in mind (that) there is no victory until after implementation, when we know our doctors are still getting paid,” AAPC’s Rhonda Buckholtz told the Talk-Ten-Tuesdays audience. “We won’t know that until probably Nov. 1, not Oct. 1. We must work to continue to show our providers that quality documentation is important moving forward, no matter what the code set is.”

Buckholtz, the AAPC’s vice president of ICD-10 training and education, said her association has trained close to 100,000 individuals on some part of ICD-10 implementation, including topics such as strategy, gap analysis, clinical documentation improvement (CDI), and coding.

“A recent survey shows that about 70 percent of our members are ready, but that still leaves 30 percent we need to bring along the way,” Buckholtz said. “We need to make sure that we leave no one behind.”

American Hospital Association

“The AHA will continue to focus on supporting ICD-10 coding education,” Nelly Leon-Chisen told Talk-Ten-Tuesdays audience members. “Our central office coding clearinghouse service has been in existence since 1963, when only hospitals were working with ICD codes. It was established by a memorandum of understanding with the Department of Health and Human Services (HHS) to collaborate and provide free assistance with ICD-9-CM advice, and we will continue to do so with ICD-10.”

Leon-Chisen explained that the AHA began providing both ICD-I0-CM and ICD-I0-PCS coding advice in 2012 while simultaneously providing ICD-9-CM advice.

“It serves as a ‘triage’ service where we provide direct advice based on established, published resources,” Leon-Chisen said. “Anything that needs additional clarification, or has not been addressed before, is referred to the Coding Clinic Editorial Advisory Board for discussion and development of a consensus opinion.”

In describing the composition of advisory board, Leon-Chisen said members include representatives from the AHA, the American Health Information Management Association (AHIMA), the Centers for Medicare & Medicaid Services (CMS), and the Centers for Disease Control and Prevention’s (CDC’s) National Center for Health Statistics.

“Since early 2014 we have solely focused on ICD-10 advice,” Leon-Chilson said. “We provide real-life application of the classification rules and guidelines based on questions and documentation sent to us by providers who have already started dual coding and are practicing coding with ICD-10.”

Leon-Chisen told audience members that the AHA’s Coding Clinic is helping to fill in knowledge gaps on code selection identified by the early adopters so that all providers get to share in the benefits from advice given when a consensus opinion has been achieved. She said questions could be submitted via the AHA online service to www.codingclinicadvisor.com.

“We also offer free coding webinars, live as well as … on demand on our website, including a couple on the Best of Coding Clinic,” Leon-Chisen said. “For the remainder of the year, we plan on (hosting) two more programs highlighting additional Coding Clinic advice, and a final one in December — post-ICD-10 implementation — on a topic to be chosen by participants.”

Nachimson Advisors, LLC

Former CMS official Stanley Nachimson, on whose watch the nation’s healthcare system migrated to the 4010 transaction set, recited from a list of five “next steps” listeners should address.

Here is the list that Nachimson, founder of Nachimson Advisors, read on the air:

  1. There are no more excuses for not moving forward on ICD-10. Everyone needs to move now.
  2. For those that have delayed, there is not much time to do the necessary work for implementation. You must focus on the critical areas. For providers, those would be documentation improvement, system readiness, and testing.
  3. Providers must determine the best way to verify the accuracy of their documentation and coding. Suggestions would include having outside experts review the work, trading off with other providers to review each other’s work, or getting some computer-assisted tools to create documentation and coding.
  4. Health plans need to publish information on their policy changes due to ICD-10 and their testing and update schedules. There are a number of policy issues (e.g. when providers will start using ICD-10 codes on prior authorizations) that are still outstanding.
  5. Providers and plans should share their testing results, especially with those that will not have the opportunity to test. We have to understand what issues are out there that need to be resolved.

The Workgroup for Electronic Data Interchange (WEDI)

“As most of you are aware, WEDI is a nonpartisan organization representing a cross-section of the healthcare industry and is named in federal law as an advisor to HHS,” Jim Daley, past chairman of WEDI, explained to audience members. “WEDI has been working on ICD-10 for over 15 years to bring attention to this initiative and to help the industry determine how to implement the new code set.”

Daley described how WEDI approached ICD-10 by creating an official ICD-10 work group in 2009. He said they began holding monthly calls to provide updates that are still going on today.

“Many of these discussions result in recommendations for new work products,” said Daley. “WEDI set up sub-work groups to address the different aspects of ICD-10 and published white papers on topics such as the overall implementation process, how to do an impact assessment, and how to use the CMS GEMs (general equivalence mappings).”

Daley said that one of the WEDI tools that would be helpful for providers even today is the WEDI Roadmap Toolkit, which provides links to key resources for each phase of the compliance process; the toolkit is available on the WEDI website, www.wedi.org.

“Currently, we have three sub-work groups dealing with transition, coding and translation, and testing,” Daley said. “Recently published items include a clarification of terminology such as dual coding and dual processing, and a paper on testing for small provider practices.”

Daley also listed other projects that WEDI is creating, including one centering on information regarding DRG shifts and a roadmap with milestones to help providers determine if they have completed certain phases. The latter tool also suggests mitigation measures for any obstacles providers might face along the way.

“We’re also developing a list of top 10 things payors should post on their websites related to ICD-10, and we’re looking to create a consolidated database of industry test results,” Daley said. “WEDI has been conducting ICD-10 readiness surveys since 2009.”

Daley said that according to the most recent readiness survey — the association’s tenth — all industry segments cited the delay as one of the biggest obstacles to being ready for ICD-10.

“WEDI will continue to provide educational opportunities and produce work products as needed through these next several months to assist the industry in final preparations for ICD-10 implementation,” Daley added.


“Like many others on today’s show, my team at Precyse has been closely watching the developments related to (the) SGR and its effect on the transition to ICD-10,” began Chris Powell, the president and CEO at Precyse. “And we have been advocating for ICD-10 on behalf of the industry and our clients for some time now.” 

Powell described an approach that Precyse took last fall to support this effort in the industry, and how Precyse became connected with an advocacy firm in Washington, D.C. to tell the ICD-10 story.

“Collectively, we have all helped raise the awareness of ICD-10 and the healthcare industry maturing,” said Powell. “We’ve heard the legislative commentary today, and as a result of everyone’s efforts, the landscape we are in is very different from a year ago, and very promising for moving forward this October.”

Powell said that there is a much broader acknowledgement of the benefits of ICD-10, which is expected to improve the overall level of clinical documentation and help move the delivery of healthcare forward.

“It is becoming increasingly clear that Congress understands that ICD-10 improves quality of care and patient outcomes, helps protect and improve public health, and offers a more rational system upon which to build repayment systems,” Powell told the audience. “For those healthcare providers, in the meantime, providers should continue to focus on clinical documentation improvement and education to prepare for an Oct. 1 implementation date.”


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.
Chuck Buck

Chuck Buck is the publisher of ICD10monitor and is the executive producer and program host of Talk Ten Tuesdays.

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