October 29, 2013

ICD-10 Readiness: Management Status Check

By Sharon Easterling, MHA, RHIA, CCS, CDIP, CPHM

We are less than a year away from ICD-10 GO LIVE and we have either not quite started, done a little, are in the throes of moving our plan along, continuing to firm up our documentation, or are getting ready to move into dual coding.

That is certainly going from one extreme to the other, but at the core of all this diversity is that we need to know where we are and have a plan in place to ensure that it is happening. You may say “I have heard that before,” and “We are doing that;” however, my hope is to take us a step further and make sure we are protected and, yes, truly ready

There are many areas that are at the top of our lists but for now, we will focus on the items below and make some considerations.

 

Does your ICD-10 implementation project have adequate oversight?

Remember, in The Lord of the Rings, Frodo knew he had to accomplish a huge task: placing the ring into the Ring of Fire. Along his journey, he was often sidetracked, exhausted, and undermined, but he knew key individuals were on his team (even though he was confused and disoriented at times) and ultimately he had to accomplish this task for survival of his world.

Right now we all probably feel much like Frodo, and we must keep our wits about us to ensure our facilities’ transition to this successfully and with few issues: business as usual. Adequate project management will help ensure this happens. Here are a few things to consider to make sure you have proper oversight involved and your needs are being met as a whole.

  • Identify your project lead—yes, some of us are still in this phase.
    •  Will this be internal oversight or external?
      • Ensure your leader has the experience needed to perform project management and drive success by staying on task and rallying the troops.
      • Do you have someone internally who may need some minimal support or leadership? If so, decide how that will happen. Many of us are so overwhelmed right now that doing this alone may not be feasible or sensible.
      • If you have selected an external vendor, are their skills adequate? Do they need oversight? Do you have clear deliverables?
      • Have the right players at the table. Remember, you may have the high-level steering committee meetings, but there will be numerous interactions and to-dos across departments. Having someone on the team who understands the revenue cycle and how this all fits will be very beneficial.

Are you considering what needs to be coded by the coding department, versus developing your GEMs and/or system mappings/conversions?

  • In a recent conversation, I realized that we all may not have had this conversation. We know we need ICD-10 training, but do we really know who needs what and why?
    • Take a good look at your revenue cycle.
      • Identify departments and really understand what they do.
      • Translate that to what they need to know. Remember registration at Hospital A may do things differently at Hospital B and may need to know more or less. There will be differences. Make sure you understand that. The cookie-cutter approach will only work for certain cookies, not all shapes and flavors.
      • After you understand how your processes occur, you may have two paths to follow: the people process (such as with coders/HIM), and the system process, utilizing mapping, conversions, or computer-assisted coding.
      • Analyze and review your documentation of those two paths and you will have documentation assessments for your people processes (such as coding) and assessments for your system conversions/translations/mappings for your chargemaster.
      • Keep in mind coders will be important in both of these paths.

Yes, we will continue to have denials and prepare for that. The question then becomes, what can we do now to plan for denials next year?

  • Assess your current denials.
    • Identify who will handle those denials that occur in the billing system prior to the bill going out the door and those denials that are coming back from payers. We should already have a process for this. How will it need to change?
    • There are now published NCDs, and MACs will be responsible for updating their LCDs. Have you assessed your documentation to ensure you will be able to code appropriately to satisfy the medical necessity edits? 
    • What about the referral/precertification, and authorization denials?
    • Denials relating to Coding of ICD-10 and Clinical Coding Validation will come. Do you plan to do what you have done in the past, or something different due to the potential increased time involved?
    • Considerations:
      • What are your current top 20 denials?
      • Why? Fix it.
      • Pull accounts, perform documentation assessment.
      • What do these codes map/code to in ICD-10?
      • Do you have needed documentation to support the code other than unspecified?
      • Determine what you can do to fill gaps.
      • Game plan for cash flow:
        • Catch up backlog
        • Work denials
        • Code everything possible prior to Go Live date of October 1, 2014, in ICD-9
        • Ensure systems are ready
        • Have ample coding support
        • Utilize ICD-10 support team champions

We wish everyone the success of Frodo, with a great deal learned as we travel the ICD-10 Implementation Highway.

About the Author

Sharon Easterling is president and CEO of Recovery Analytics.

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References:

http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM8207.pdf

ICD-10 Revenue Cycle Impact. Sharon Easterling, MHA, RHIA, CCS, CDIP, CPHM.  NCHIMSS ICD-10 Summit; September 2014.

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.