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

I have been traveling the past month, presenting ICD-10 awareness information to various groups, including hospital boards of directors, hospital executives, and physician groups.  I find it interesting that many still don’t understand how ICD-10 will impact each and every organization, and that some executive stakeholders apparently do not really comprehend what ICD-10 really is.

 

This is the reason I think so many are lagging behind, thinking that “this is just information systems and coding training, so what’s the big deal?” But ICD-10 is a very big deal.

What can we do to make all healthcare organizations – from hospitals to physician practices to long term care, etc. – understand the enormity of this transition? The bottom line is this: if you are not ready to submit ICD-10 claims on Oct. 1, 2014, you will not get paid. It is as simple as that. So if you have not begun your impact assessments, time is running out – and in order to get to the phase of executing an action plan, which may take several weeks or even months, you better start planning today.

I am still amazed that I am getting calls from hospitals and physician groups inquiring about services to assist with ICD-10 implementation. But there is a glimmer of hope. If you are part of a small hospital or a physician group, you still have time to make it, but just barely. There is so much to do. Think about it. Take a six-step approach now, and it can be done – but, because you waited so long, it will not be without many challenges along the way.

Here are the six fast-tracking steps you should take if you have yet to execute an action plan:

  1. Planning for ICD-10
  2. Ensuring communication and awareness
  3. Assessment
  4. Operational implementation
  5. Testing
  6. Transition

Let’s look at each step briefly.

Planning:

You have to begin planning for ICD-10 immediately, a process that includes establishing your project management structure, planning a comprehensive ICD-10 budget, getting all the relevant stakeholders committed and involved in the project, and contacting vendors, clearinghouses, and all business associates and trading partners that will be involved in the transition. This in itself may take considerable time and effort. From there, you need to develop an ICD-10 implementation timeline, keeping in mind, again, that you need to be ready to go live on Oct. 1, 2014.

Communication:

This means developing a communication plan – not just internally, but a comprehensive plan to communicate with payors, vendors, government agencies, customers, staff, patients, etc. Put the plan in writing and develop a communication schedule.

Assessment:

Conducting an impact assessment is an important step that is not to be overlooked. This involves examining each department’s workflows, software applications, roles of staff, and reporting – all of which can raise questions you may not have considered before, such as “who executes the ABN?” Has a staff member been trained to execute the ABN? What reports does each department produce? Are physician orders on paper or kept in electronic form? Where does each staff member get the diagnosis from (physician orders, superbills, charge sheets, etc.)? These are just a sample of the questions departments should answer in order to get a clear picture of the “as is” state of each, which allows you to determine what gaps exist that need to be filled prior to the ICD-10 deadline?


Also prepare a list of all your vendors and assess their ICD-10 readiness, including your clearinghouses, electronic health record managers or other software application or business associates. If they cannot be ready in time, you will need to find an alternative quickly.

It is not just about the coding, as I stated earlier. Everyone needs training, whether in awareness, anatomy and physiology, ICD-10 fundamentals, ICD-10 documentation or advanced ICD-10-CM/PCS studies. The type of training each person should get depends on his or her role in the organization. Building training plans may be more time-consuming than you think, and it will involve talking to various staffers and/or departments to analyze their training needs. Then you have to think about overtime, filling vacancies when others are in training, costs of training, where you will get training, etc. For a large group, this can take months, or it could take just weeks for a medium-size organization.

Operational Implementation:

Development of an action plan must include everything you must accomplish prior to Oct. 1, 2014, along with deadlines and ownership of each task. Making sure the action plan is executed properly and timelines are met should be delegated to a group of project manager.

Don’t always assume it is only the health information management (HIM) director or practice managers who should fill this role.

Physician documentation training should be occurring now, or no later than the last quarter of 2013. Obtaining ICD-10 coding training should begin no later than the second quarter of 2014. If you plan to begin dual coding in April 2014, it is best to begin training sooner. Keep in mind that there will be a training offering shortage, so secure your training method and source now. Also included in this step should be anticipation of risk, specifically by creating a risk strategy to mitigate the financial pitfalls inherent in ICD-10 implementation. Action plan execution should begin, at the latest, by Jan. 1, 2014, if not sooner. I would not wait. Also, making business and operational changes or modification should occur at this time.

 

Testing: This is the process of proving that a system or process meets the requirements presented by ICD-10 and produces consistent and compliant results. This is critical to successful implementation. Testing will ensure compliance across internal policies, processes and systems, as well as with external trading partners and vendors. Testing should be conducted internally, externally and in end-to-end fashion, and it should begin in the first quarter of 2014 – so timing is crucial. Testing should continue until Oct. 1, 2014 at a minimum, and possibly even beyond, if issues are uncovered.

 

Transition: A contingency plan should be developed before Oct. 1, 2014 in order to identify potential coding backlogs, losses of productivity, documentation deficiencies and payment delays. This will allow for the successful handling of those critical issues that will affect revenue if not remedied. During the transition phase, we will be in the last couple of months preparing to go live with ICD-10. But the transition phase may last well into 2015 while we resolve all the issues either not addressed or not anticipated prior to the big shift.

As I tell many practitioners and hospitals in the industry, this will be one of the most challenging transitions healthcare has yet to encounter, and proper planning is the key to success. So as you can see, with so many tasks to accomplish and so much to do, lagging behind only will affect your bottom line and potentially impact payment and reimbursement once ICD-10 becomes a reality. So if you are lagging behind now, it is time to take the first steps toward ICD-10 implementation. Get going, before it is too late. Don't count on another delay – doing so would be gambling with the health of your organization.

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

Deborah Grider has 34 years of industry experience and a recognized national speaker, consultant and American Medical Association Author who has been working with ICD-10 since 1990 and is the author or Preparing for ICD-10, Making the Transition Manageable, Principles of ICD-10 and 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 Literacy Legacy Award Recipient. She is a member of the ICD10monitor editorial board and a popular panelist on Talk Ten Tuesdays.