March 3, 2014

ICD-10: As Clock Winds Down, Where to Focus?

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We are at the 11th hour of ICD-10 industry transformation, and yet we still are talking about what I-10 codes are, how to do an assessment, how much does they cost to implement, and how to implement them.

The healthcare industry will continue to see facilities and providers, etc. work through, and in some cases struggle to meet, the compliance date. We also know that there are application vendors who are just now releasing their ICD-10-ready products. And there are many large application vendors across the industry who state their products are ICD-10-ready, but not -compliant. We know that improved clinical documentation to align with the new coding system is still being worked through across the healthcare delivery system.

But the time has run out on the clock. When I wrote this, we had 289 days left to compliance date. So where do we now focus our efforts as an industry? I would argue it should be primarily on risk mitigation and business continuity. We need to recognize and accept that even if payers, health systems, hospitals, and/or physician practices do everything they can do to meet the challenges of ICD-10 internally, when it comes to external business dependencies, there are considerable business risks.

It is naïve to think any organization will be free of business risk if only applying an internal strategy. Now is the time to initiate or strengthen the B2B and B2C relationships, especially to ensure they are sustainable through compliance date.

As we enter the 11th hour, we need to change the discussion to a “call to action” and begin the risk mitigation process. Surveys show there is a segment of the healthcare ecosystem that has not started or is considerably lagging in the move towards ICD-10 compliance. The call to action needs to be heard by every segment within the healthcare ecosystem. The following are some steps that are a part of a comprehensive risk process:

  • Identifying and safeguarding the mission-critical business functions

  • Applying a weighted factor to the core process to reflect its criticality to the business

  • Reviewing and fast-tracking projects in flight that are mission-critical

  • Evaluating and protecting the supply chain (including providers, pharmacies, diagnostic labs, consumers, suppliers, etc.)

  • Conducting legal risk assessment

  • Initiating litigation planning and issues’ resolution

  • Developing contingency plans and fallback procedures

  • Assembling a complete inventory of all external business relationships

  • Creating legally binding agreements with application vendors to document delivery date for ICD-10

  • Conducting and establishing a resource readiness assessment to align staffing needs with resource availability

It is important to get beyond creating surveys, especially when looking to vendors’ readiness, as it can take until October 2014, in some situations, to implement software upgrades. Surveys continually show that most vendors will not set a release date, while some have set release dates for the first or second quarter of 2014. The question to be asked of some of the smaller vendors is whether they will ever meet the date to position their clients for compliance. But to survey without follow-up action will not meet your IT and system challenges.

The external relationship along the healthcare supply chain goes from a sole practitioner to multimillion-dollar hospital systems, from global pharmaceuticals to mom-and-pop-type pharmacies. The diversity magnifies the potential of the impact of various stages of readiness. During the risk mitigation process, it will be important to look at a replacement strategy for external partners, should you need to replace one whose lack of readiness might have significant impact potential on business continuity.

While replacement may not be a part of the process during the switchover and during the first 12 months post-compliance date, being prepared with alternatives is part of due diligence. A tiered strategy in creating an approach for managing provider relationships from the 11th hour to 12 months post compliance date and into past release of “code freeze” will be crucial.

It will be important to review the criticality of all external relationships, identify potential impact due to I-10 transformation and how important the relationship is to business continuity, and then set a course of risk mitigation. This should include an assessment to establish the importance of the relationship to business continuity, on a scale of less important and/or to critically important; an informative communication plan; questionnaires to assess status; and establishing a focus group of the most critical external partners to overall transformation success, which should produce a risk mitigation plan which will be the foundation for business continuity. No organization, provider, supplier, health plan, P&C carrier, or auto medical carrier is too small or should not be considered a risk due to its status as a non-covered entity. Just how great or small a risk needs to be identified.

As you read this, you might be thinking that is this an extreme reaction. After all, we have been using the codes for more than 30 years as the foundation for healthcare in the U.S. But we also know that the U.S. healthcare system has not embarked on such a dramatic change in the history of modern healthcare. We also know that this is not the only event or regulation that the industry is faced with, and that all the moving parts of healthcare in the U.S. are not moving forward together. I know many of us call this “the Y2K of healthcare”—but remember, Y2K essentially turned out to be a non-event; in hindsight, we now know that the potential risk of that transition drove industries to over-plan. That was the good news of Y2K; let’s make it the good news of I-10 transformation and sail past the October 2014 compliance date with ease.

About the Author

Ellen VanBuskirk, senior principal in business consulting for Infosys Public Services, is a healthcare consultant focused on compliance strategies with a mission to work across the healthcare value stream to meet regulatory challenges. VanBuskirk has conducted business development efforts in support of healthcare compliance and reform, as well as ICD-10 transformation by both provider and payer organizations. VanBuskirk brings deep expertise in health plan regulatory and compliance initiatives, including healthcare reform, ICD-10 transformation, meaningful use, HITECH and HIE.

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Ellen VanBuskirk

Ellen VanBuskirk is the national director of healthcare practice with Slalom Consulting and has held executive positions in provider, payer, and managed care organizations. She started her career in clinical delivery with an expertise in emergency medicine. Ellen brings her expertise of working for many years on the U.K. National Health Service Modernization Program, as well as her experience of working on global and domestic healthcare program change for her clients.