Coping with Another ICD-10 Delay: Going from Limbo to Quid Pro Quo

By Juliet A. Santos, MSN, CCRN, FNP-BC
Original story posted on: April 7, 2014

Although ICD-10 implementation experts gained momentum to meet the ICD-10 compliance date of Oct. 1, 2014 after a delay was announced in 2013, they are once again in limbo.

If you’ve been entrenched in ICD-10 since January 2009, when a scheduled implementation was first announced, do your best to maintain your health despite the recent congressional vote to pass H.R. 4302, titled “Protecting Access to Medicare.” The decision to add one fateful line in this bill generated sighs of relief for many providers, and conversely sighs of exasperation for those who have been working hard to address the biggest transformation to impact healthcare in the last 34 years.

Implementing a massive mandate such as this, having no real end date, can drain organizations that in some cases have invested millions of dollars to be compliant. Still, those who have begun earnest efforts to comply with the federal mandate to implement ICD-10 must take heart. They must resist the temptations to stop all efforts, reallocate resources to competing priorities, and shelve ICD-10 altogether until the new deadline … whenever that may be. They must combat mental and physical fatigue to continue working on something that never seems to end.

Organizations that were on track to be compliant by Oct. 1, 2014 should adhere to their project timelines. Coping mechanisms to enable a seamless transition include:

  1. Focus on and conduct:

    1. Thorough assessments (Have you missed any systems that need to be remediated?)

    2. Well-planned implementations (Having the right resources could be half the battle)

    3. Systems remediation (The release dates must be firm, and not continuously extended)

    4. Investments in multiple cycles of testing (Testing once is not enough — be sure to test again)

  2. Extend a helping hand to smaller provider groups within your organization to ensure that no one is left behind. It’s time for a little quid pro quo. After all, physician groups are the feeder mechanisms to hospitals of all sizes. Isn’t it worth it for the industry to rally behind its providers? Assisting providers may even break up the monotony of implementing ICD-10 for organizations that have been internally focused instead of externally focused.

  3. Review why we need to transition to ICD-10 and understand how this will impact population health. Upgrades are never easy or negligible in cost, so it is important to remember this in order to avoid losing focus.

  4. Account for ICD-10 expenditures to date and carefully track the impact of another one-year delay to your organization. Be aware of the costs of resources, dual-coding training needs for staff, and what is necessary to maintain the capability to keep ICD-9 going while upgrading to ICD-10. Monitor the costs of delay to your organization in the event that the Centers for Medicare & Medicaid Services (CMS) conducts an industry query to report to the U.S. Senate or President Obama.

  5. Select vendors that best meet your enterprise’s needs and complement your culture.

  6. Audit coders to determine accuracy rates and productivity.

  7. Monitor/conduct internal audits of providers’ clinical documentation to verify that ICD-10 codes can be supported and defended in the event of RAC audits.

  8. Audit cash flow to ensure ample financial reserves during the period immediately following implementation.

  9. Support and champion internal and external testing. This is a QA process that cannot be circumvented or eliminated. Use the extra time to conduct thorough end-to-end testing with trading partners as often as possible.

  10. Set up dashboards to monitor your financial KPI — adjudication rates, paid claims, denied claims, pending claims, and other metrics important to your success.

Seriously Consider Quid Pro Quo

As the industry awaits whatever is coming next, avoid making any sudden changes in the course of your ICD-10 preparation. If you are far along in your preparations, you will fare well being done rather than stopping your momentum suddenly only to have to restart it closer to the new deadline. The “start, stop, start, stop” approach is inefficient, obliterates momentum, and wastes energy and resources. Although industry motivation might begin to wane, stay on course despite the delay, complete the implementation, and increase the frequency of planned testing cycles to ensure a flawless production performance.

Finally, the healthcare industry should seriously ponder the root cause of these delays — especially those who are lagging behind, perhaps due to lack of people and financial resources, among other reasons. Organizations in a position to extend a hand to providers should do so immediately. Look around and learn more about the many small provider groups that may require additional assistance. After all, ICD-10 is an industry-wide initiative. Healthcare systems are directly impacted by the ability of smaller provider groups to admit patients into their facilities, perform procedures, order diagnostics, and take care of other essentials to patient care – –all of which are revenue-generating. It is in the best interests of the healthcare system that small physician groups are successful in embracing ICD-10.

Again, this may be an opportunity to forge a quid pro quo relationship, and there may not be a better time. The healthcare industry needs to complete ICD-10 and move on to other, more important initiatives affecting the health of patients. Being in limbo is dangerous to the industry’s ability to solve other issues.

Regardless of the ICD-10 final date, avoid being in limbo by staying focused on completing ICD-10 – and use the extra time wisely. By the time the next deadline arrives, healthcare systems and smaller physician groups should all cross the finish line with no one left behind. Quid pro quo is the only way to go.

About the Author

Juliet Santos is the ICD-10 principal consultant for Leidos Health, a healthcare IT consulting company. Santos formerly was EVP of Lott QA Group and assisted with the creation of ICD-10 National Testing Platform.

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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.