Updated on: March 14, 2016

Exclusive: ICD-10 Implementation – Where Do We Really Stand?

Original story posted on: June 9, 2014

EDITOR’S NOTE: Rhonda Buckholtz is testifying today before the National Committee of Vital Health Statistics.

It appears that the coding industry is much more ready for ICD-10 than previously believed, and the cost to prepare is proving less expensive than was claimed by other sources, recent AAPC studies indicate.


As I prepared for my presentation at June’s National Committee of Vital Health Statistics (NCVHS) meeting, I surveyed 5,000 AAPC members and others in the industry via the Internet and by phone. Members of the survey group, many of whom had attended AAPC ICD-10 trainings, largely said they were more prepared at less cost than what was being reported elsewhere. However, they also revealed testing concerns and fears about the implementation.

A Matter of Readiness

The survey was particularly illuminating in light of the ICD-10 implementation delay imposed by HB4302, which was signed by President Barack Obama on April 1. With only a few days’ warning, the law postponed implementation to no earlier than Oct. 1, 2015. What does that mean for the coding community? How ready are they?

Nearly three-quarters of the aforementioned survey respondents were well on their way. One-quarter of those surveyed had completed all ICD-10 training, 13 percent indicated that they were ready to go, and 23 percent were actively testing with vendors when the bill was signed. Only slightly less than a third were still in the beginning phases of preparation.

Survey respondents also had a somewhat complicated story to tell about testing. While 70 percent noted that they were ready to test, 20 percent indicated that they were not, and 10 percent did not know. Pushed for details, 38 percent reported that they had done some type of testing already, but 48 percent had not done any yet. A mere 8 percent said their vendors were not ready to test.

Respondents are concerned about a number of issues related to implementation. While many are naturally worried about another delay in implementation, others worry about training physicians and opposition from the the American Medical Association. But unclear messaging from the Centers for Medicare & Medicaid Services (CMS), mixed messaging, and credibility issues are weighing on them. Problems with vendors, including the possibilities of late electronic health record (EHR) upgrades and testing woes, add to the worries tied to claim delays.

The Cost to Prepare

AAPC has trained more than 90,000 people in ICD-10, including in arenas of implementation, education, mapping, and consulting. Past clients were asked about the true cost of implementing ICD-10 in their practices or facilities. This only could be answered by those who were truly ready, and does not account for any additional funds that may now be needed to address the delay. We found that those who utilized AAPC had significantly fewer implementation costs than what has been reported elsewhere in the industry. We broke it down into three groups and the costs were determined by how much vendors charged, how much they spent on education, and how much was spent on consultants:

Small practices (defined as under 10 providers)

  • Implementation costs averaged $750 per provider

Medium practices (defined as 10-49 providers)

  • Implementation costs averaged $575 per provider

Large practices or organizations (defined as 50 or more providers)

  • Implementation costs averaged $3500 per provider

On average, ICD-10 is costing a provider about $1,600. These are actual costs that do not account for staff time spent during training and education, and the costs represent clients who were able to provide us their data. I believe that perhaps we as an industry should perform more of these surveys to find out how much has truly been spent per provider.

About the Author

Rhonda Buckholtz is vice president of ICD-10 education and training at AAPC. She has more than 20 years experience in health care, working in the reimbursement, billing and coding sector, in addition to being an instructor. She is responsible for all ICD-10 training and curriculum. She has authored many articles for health care publications and has spoken at conferences across the country. She is a co-chair for the WEDI ICD-10 Clinical workgroup and has provided testimony ongoing for ICD-10 and standardization of data for NCVHS. 


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.

Rhonda Buckholtz is the vice president of practice optimization for Eye Care Leaders. She has more than 25 years of experience in healthcare, working in the management, reimbursement, billing, and coding sectors, in addition to being an instructor. She is a past co-chair for the WEDI ICD-10 Implementation Workgroup, Advanced Payment Models Workgroup and has provided testimony ongoing for ICD-10 and standardization of data for NCVHS. Rhonda spends her time on practice optimization for Eye Care Leaders by providing transformational services and revenue integrity for Ophthalmology practices. She was instrumental in developing the Certified Ophthalmology Professional Coder (COPC) exam and curriculum for the AAPC. Rhonda is a member of the ICD10monitor editorial board and makes frequent appearances on Talk Ten Tuesdays.