Updated on: September 23, 2013

ICD-10 Readiness: Emerging Trends

Original story posted on: October 16, 2011

As someone who works with both healthcare payers and providers, I have the opportunity to speak with a wide range of organizations about their readiness for ICD-10.  A few trends have emerged from these discussions.

First, the larger the organization, the better organized they are and the more aggressive they are about being ready long before the October 2013 deadline. Generally speaking, they believe that they will need the extra time to fix problems and develop contingency plans—a hope for the best but prepare for the worst philosophy.

Second, payers seem to be in good shape, in part because the largest organizations that must deal with ICD-10 are payers. They are further ahead in part because they have more resources than their smaller counterparts. Impact assessments have long been completed and put into programs.

Third, most providers are worried that their organizations are behind.

It’s easy to see why providers are concerned. ICD-10 is just one of many mandates that providers need to address. The deadline for ICD-10 comes after electronic health records, meaningful use and ACO among the many mandates that providers must address.

Same Ten People

In addition, providers are generally smaller than payers and their smaller staffs are getting stretched thin by all of these initiatives. I have heard it referred to as the “STP problem” —the same ten people are deeply involved in each of these initiatives.  Also, the providers recognize that their revenue will be in jeopardy if they do not implement ICD-10 properly.  Finally, ICD-10 is not just an IT problem.  It will require training and changes in workflow and how medical professionals have done their jobs.  These changes can be much more difficult to manage.

Are these concerns justified?  The healthcare industry does not have experience with equivalent transitions. There simply is limited institutional knowledge to draw on and the “unknown unknowns” are a legitimate cause for concern.  There is one objective way to know how well organizations are doing.  There are best practice models for ICD-10 from organizations like the Workgroup for Electronic Data Interchange (WEDI) and the Centers for Medicare & Medicaid Services (CMS). For providers, the most comprehensive model available now is the ICD -10-CM/PCS Transition Planning and Preparation Checklist from the American Health Information Management Association (AHIMA), which describes it as follows.

This resource has been developed to assist all types of facilities in the implementation of ICD-10. Although designed from the perspective of a complex healthcare organization such as a large acute-care hospital, the checklist can be scaled down easily for any type of smaller organization.

Best Practice Model

This document is a detailed timeline of what a provider should do and when it needs to be done.  It is a template for a project plan as much as it is a checklist.  According to the best practice model, providers should have done the following by now.

  • A steering committee should be formed, and a project manager should have been assigned.
  • Stakeholders should have been educated on the ICD-10 transition.
  • Organizational impact assessment should have been conducted.
  • There should be a budget for the transition.
  • Business associate readiness should have been assessed.

In total, the model outlines 30 key steps. Of this total, 19 should have been completed by now.  I have spoken to providers who have not yet conducted an impact assessment and others that have not even engaged their information technology (IT) vendors.  How badly is the industry lagging?  Organizational impact assessments should have been completed by the end of the first quarter of this year.  However, a WEDI survey in January indicated that fewer than half of providers expected to be done on schedule.

Testing with Trading Partners

While ICD-10 is not exclusively an IT problem, there is a significant IT component to the transition.  At a high level, healthcare organizations need to ensure that their IT systems and service providers can support ICD-10.  It will be necessary to do testing with trading partners to validate compliance with ICD-10.  This will take time.  If providers can learn one thing from the best practices being implemented by payers, it is to focus on vendor readiness right now.  The best practices models put vendor readiness early in the process because they are early in the critical path of your transition.  For example, AHIMA suggests that this should have been completed by the end of 2010.

In a statement to the Department of Health and Human Services (HHS) in June 2011, WEDI noted:

Survey results indicated that many vendors were not planning to deliver products until 2012 or even 2013. This limits the amount of time that entities will have to install and test these products internally as well as with trading partners.

If your vendors are not ready, you can’t do your testing, and your organization will be at risk.  Providers need to understand what to expect from their vendors.  This will drive the timelines of what you can actually accomplish.

About the Author

Hugh Kelly is the Vice President of Marketing and Sales for Avior Computing.  Mr. Kelly has more than 20 years in the software and technology business at organizations ranging from start-ups to publicly traded companies. Mr. Kelly has been involved in all aspects of marketing and sales, with considerable focus on channel development.  During his executive tenure, his organizations have raised over $200M in external capital.  He is a venture partner at Ascent Ventures.

EDITOR'S NOTE: Mr. Kelly is the author of a white paper on managing trading partner and affiliate readiness.

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