logo Print this page
Updated on: March 14, 2016

Fast Tracking ICD-10: Building the Action Plan

Original story posted on: July 19, 2013

EDITOR’S NOTE: This is the fifth in a series of articles on fast-tracking ICD-10 implementation.

It time to get geared up for ICD-10 by building an action plan. We just finished developing a budget for a large hospital system and found that the bulk of the budget will go to software applications, hardware upgrades, and education and training. These also happen to be three high-risk areas as it pertains to compliance.


Now we have to turn the impact assessment and gap analysis into the action plan. I am finding that working with hospital systems that have large steering committees with several sub-committees helps distribute the action items evenly. For example, every department will need education, whether in the form of simple awareness, fundamental instruction, documentation courses or in-depth training. By assigning this task to the education subcommittee, an organization can map out an education plan listed front and center in the action plan. I find that, for large health systems and hospitals, it is helpful to map out action items and milestones in an Intranet portal so every steering committee member and subcommittee chair can track progress along the way.

How do you begin this process? First, start with a simple spreadsheet identifying the following:

  • Business areas or departments
  • Action items
  • Start dates
  • End dates
  • Durations (estimated time for completion)
  • Responsible committees or persons

Below you can see an excerpt of an action plan with steps that should be taken for implementation (though this is not all-inclusive).

Business Area


Start Date

End Date



Information Systems

  • Update systems to support patient flow processes and background operations, and execute comprehensive testing
  • Upgrade all software applications impacted by ICD-10 (see application list)
  • Investigate interfacing software with EHR




Information systems-director and subcommittee

Education and Training

Develop education and training plan for all staff, including health information management (HIM) and physicians

  • Determine where to obtain training
  • Budget for training
  • Obtain training





Education subcommittee

Hardware Upgrades

  • Meet with vendor to discuss upgrading hardware based on requirements obtained from EHR vendor




Information systems-director

Finance/Revenue Cycle

  • Create mitigation plans to address billing delays, slowdown in payment processing, denials, coding error rates, documentation issues, etc.




Patient financial services subcommittee

Medical Records

  • Develop response to new information demands, continued education and training on code sets





Health information management subcommittee



Business Area


Start Date

End Date



Cost and Reimbursement

  • Ensure grouper is complaint, upgrade to version 16.0
  • Standardize building of scorecards and executing more consistent calculation
  • HPM extract may need to be rewritten for ICD-10
  • Currently, there have been code changes after claim submission due to different groupers in HPM and EHR; develop process for avoiding or eliminating this problem
  • Combined patient accounts are not being combined, causing grouper differences;  develop protocol for combining accounts (for 72-hour rule)
  • Remember that patient accounts and HIM need to develop a workflow when your insurance carrier changes the DRG
  • Create a better process with CDI to ensure that claims are not released when queries are pending; develop a work queue in Epic to ensure that staff review the claim before the bill is submitted




Finance subcommitte

Information systems is a department that should have its own action plan that ties into the hospital’s or physician practice’s action plan. Such a specialized plan should identify all software applications and which departments use each particular software application upgrade, also listing dates, interfaces, and parameters for internal testing, external testing, and end-to end testing.

Information systems have a big task ahead. In my experience with hospital systems, such departments sometimes utilize up to 40-50 software applications. Some applications interface with each other, some do not, and only a limited number have the capability to interface with the electronic health record.

Once the overall action plan and the information systems action plan are developed, the real work begins. Action items should be assigned to individual subcommittees (some of which are referred to by some health systems as “action teams.”) Each subcommittee should take each action item and cross-reference it against the impact assessment and gap analysis to determine how it will accomplish its goals.

Each subcommittee should map out a plan to complete each action item and present its findings to the executive steering committee within 30 days of receiving assignments. It is important to allow at least a month for the committees to develop the action items, giving them time to think through the process and develop their plan.

Again, progress should be updated on an Intranet or ICD-10 portal so the entire steering committee can review progress in between meetings. Keep in mind when creating such a portal that it should be password-protected, meaning only the executive steering committee and authorized subcommittee members have access.

Since many organizations have limited meeting time, using a portal allows the executive steering committee to review the reports in advance and prepare questions and comments before the meeting so things can progress in a timely manner. No one has time to sit through a four-hour meeting, so organization is important in keeping the steering committee engaged and interested.


As I have indicated in the past, the steering committee should meet monthly, at a minimum. When the ICD-10 implementation deadline draws closer, the steering committee should be meet on a weekly or biweekly basis.

So, where are we in the execution of the action plan? We presented it to the executive steering committee, which reviewed and approved the action items. Subcommittees were developed, with a chairperson assigned for each. Each subcommittee chair submitted a list of members of his or her group for steering committee approval. Meetings were scheduled for each subcommittee to discuss objectives of the action items. Right now these groups are in the process of developing a plan of action for each item, along with timelines for completion.

What’s next? Once the subcommittees develop their plans of action for their action categories, they will upload them to the portal for the next executive steering committee discussions. Once the plan for each action item is approved, it will be time to begin execution of the items. This is where it gets really tough, keeping everyone on task within the timelines. It is difficult to stay on task when there are so many competing issues in healthcare right now, and each project manager has a huge task of making sure we stay on track. Monitoring progress and milestones is critical for ICD-10 implementation.

Executing the action plan will begin the march toward successful implementation.

The fun is just beginning!

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.
Deborah Grider, CPC, CPC-H, CPC-I, CPC-P, CPMA, CEMC, CCS-P, CDIP, Certified Clinical Documentation Improvement Practitioner

Deborah Grider has 35 years of industry experience and is a recognized national speaker, consultant, and American Medical Association author who has been working with ICD-10 since 1990 and is the author of Preparing for ICD-10, Making the Transition Manageable, Principles of ICD-10, the ICD-10 Workbook, Medical Record Auditor, and Coding with Modifiers for the AMA. She is a senior healthcare consultant with Karen Zupko & Associates. Deborah is also the 2017 American Health Information Management Association (AHIMA) Literacy Legacy Award recipient. She is a member of the ICD10monitor editorial board and a popular panelist on Talk Ten Tuesdays.

Latest from Deborah Grider, CPC, CPC-H, CPC-I, CPC-P, CPMA, CEMC, CCS-P, CDIP, Certified Clinical Documentation Improvement Practitioner

Copyright © 2021 | ICD10monitor.com, a division of Panacea Healthcare Solutions, Inc.
287 East 6th Street | Suite 400 | St. Paul, MN | 55101 • TOLL FREE: 800.252.1578