ICD-10: It’s Déjà vu All Over Again

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Original story posted on: March 30, 2014

I’m writing this article on Friday, March 28, so I have no real insight into what might happen next week into what might happen next week as the U.S. Senate votes on the House-approved “doc-fix” legislation that includes a controversial paragraph that would extend the ICD-10 implementation date to Oct. 1,2015. I suspect that we’re looking at another one-year delay, but anything is possible, and my crystal ball has been on the fritz ever since I filled out my NCAA bracket.

I’m feeling a sense of déjà vu, as I’ve written a few ICD10monitor articles about delays and impacts in the past, including:

  • “ICD-10 Delay Seen as Positive to Some” (Tuesday, April 17, 2012), written in reaction to the last one-year delay. This article explored the relief felt by most at finally having some guidance after a few months of hinted delay. This latest delay is a bit more merciful, from this perspective (only a few days of angst, as opposed to a few months).

  • “The Pauser’s Dilemma” (Tuesday, Sept. 24, 2013), which described some of the challenges faced by companies that chose to “pause” or halt their ICD-10 programs when the last delay was announced.

  • “ICD-10: The Home Stretch?” (Tuesday, Feb. 18, 2014), which explored where we really were at with ICD-10 implementation. I wasn’t of a mindset that we were in a home stretch last month, and clearly, we may be one year farther away from the home stretch than we were last week.

Many of our clients are already contemplating what to do, assuming that the legislation passes and we do indeed have a new mandated date. While our advice is always client-specific, there are a few consistent themes that we’re preparing to share with our clients (and readers!) I’ve summarized these below.

  • ICD-10 will happen eventually – just as with other mandates that have slipped dates multiple times (HIPAA 5010 comes to mind), the ICD-10 mandate will not simply go away. Completely stopping all work for most ICD-10 programs doesn’t make sense.

  • Re-evaluate your ICD-10 implementation plan in terms of readiness. If a slower burn and/or pause are considered, be sure to quantify the cost of restarting your program, including the risk of lost institutional knowledge and re-work.

  • In the last delay, “pausers” fared worse than “slower burners” – when the last delay became a reality, some companies fully halted their ICD-10 programs (“pausers”) and other companies slowed their programs, but continued some or most work streams (“slower burners”). Slower burners maintained some momentum and progressed toward the remediation requirements, and they subsequently had an easier time ramping up their ICD-10 programs. Pausers are likely breathing a sigh of relief at the prospects of another delay, as their programs were mostly in a “death march,” with unlikely completion of all remediation activities by Oct. 1, 2014. We believe that the right response to a delay is not to fully pause, but to reduce the team size and burn rate to a lower level.

  • The work streams that are most likely to sustain effort and should continue include:

    • ICD-10 custom mapping development, testing and analysis (e.g. DRG shift)

    • ICD-10 system remediations that are significantly behind

    • ICD-10 clinical documentation improvement programs and/or physician education in support of remediation efforts

About the Author

John Wollman is the Executive Vice President of Healthcare for HighPoint Solutions, a Management and Information Technology consulting firm focused on Healthcare and Life Sciences.  John is responsible for HighPoint’s Healthcare industry group, catering to Payers and Providers.  John is a recognized expert in several healthcare business domains (Reform, HIPAA 5010, ICD-10, Platform Strategy) and technical domains (Master Data Management, Analytics).  Since graduating from Duke University, John has held executive level positions at consulting and technology companies over his 25 years in business.

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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.