June 23, 2014

ICD-10 Road to Recovery: Credibility, Collaboration and Communication

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As soon as Congress announced the latest ICD-10 implementation delay, healthcare industry leaders from across the country rallied together to face the facts (not to mention their collective disbelief and disappointment) and figure out how to move forward.

First there was the April 30 ICD-10 Summit organized by the Workgroup for Electronic Data Interchange (WEDI) and others to develop an industry action plan for ICD-10 implementation.

 

As a follow-up to the summit, WEDI submitted a June 4 letter to the U.S. Department of Health and Human Services (HHS) secretary outlining what it called a “high-level ICD-10 transition roadmap.” (To view this letter, go online to http://wedi.org/docs/comment-letters/icd-10-summit-letter-to-hhs--06-04-2014.pdf?sfvrsn=2.)

Next came an opportunity for industry leaders to present testimony at the June 10 hearing of the National Committee on Vital and Health Statistics (NCVHS) Subcommittee on Standards — a federal advisory committee that collects industry input, digests it, and makes recommendations to the HHS secretary.

Many of those who presented testimony to the NCVHS, including Nancy Spector, director of electronic medical systems for the American Medical Association (AMA), then joined the June 17 broadcast of ICD10monitor’s Talk Ten Tuesdays. They shared their organizations’ perspectives on how the industry is coping with the fourth implementation delay, as well as what must be done to make it through the latest transition. And Dr. Devon Jopp, WEDI’s president and chief executive officer, summarized the key points of the organization’s ICD-10 transition roadmap.

Stunned and Stalled

Sue Bowman, senior director of coding policy and compliance for the American Health Information Management Association (AHIMA), noted that the latest delay has resulted in the “loss of forward momentum among those who wouldn’t have been ready for this year – and even those who would have been ready for this year are now slowing down or stopping their work altogether and may not be ready for next year.”

Bowman also noted the increasing implementation cost associated with each year of delay, saying that “some members and stakeholders have told us that this delay may translate to a 30 percent cost increase for many organizations, based on their experience with the last delay. (The) industry has dedicated a lot of time and resources with system changes, workflow changes, conversion work, documentation improvement, and training, and those costs will increase with redo of conversion work.”

The Credibility Gap

Tim McMullen, executive director of the Cooperative Exchange, sat in the audience during the NCVHS testimonies and noted that many of the speakers cited credibility issues associated with the aforementioned matters. Holly Louie, chair of the Healthcare Billing and Management Association’s (HBMA) ICD-10/5010 Committee, was one of those speakers.

“We have a major credibility problem surrounding ICD-10,” Louie said during the broadcast. “If it will happen at all, when will it happen — but, more importantly, I think (there are) issues (surrounding) if or when it does happen, will it be successful? And the fears about the negative impact to cash flow.”

McMullen also observed that speakers had a wide range of opposing opinions, but most of them were on the same page about the solutions. “The industry needs certainty, or as much certainty as you can get, that the October 1, 2015 date is real,” he said. “Otherwise, stakeholders won’t move forward.”

Momentum is, in fact, at the forefront of the minds of several industry leaders, including Stanley Nachimson, principal of Nachimson Advisors, who spoke about the need to “do things differently to assure that the industry will effectively meet the October 1, 2015 deadline.”

Discussion at the WEDI summit included this question, said Nachimson: How do we engage the industry and get them moving so we’re not faced with a crisis next fall and so there is not a call for any further delays?

“WEDI is recommending that we find out what it is that people are objecting to about ICD-10 … and to work with groups that haven’t been engaged and those that don’t want ICD-10,” he said.

The AMA’s Position

One of the most verbal opponents of ICD-10 has been the American Medical Association (AMA), which continues to hold fast to its policy of advocating for a stop or delay to ICD-10 implementation. Nancy Spector, the AMA’s director of electronic medical systems, joined Talk Ten Tuesdays to share the highlights of the association’s NCVHS testimony.

Most importantly, the AMA believes its concerns are “fundamental” and include implementation costs, transition problems, and industry readiness, she noted. And as Spector explained, the AMA views ICD-10 as an unfunded mandate that comes at a time when physicians are trying to meet several other federal requirements, including meaningful use in addition to the physician quality reporting system (PQRS) and the value-based modifier program.

Physicians who do not meet these requirements risk cuts to Medicare reimbursement, and these are, says Spector, “significant cuts on top of the 2 percent sequestration reduction now in effect.” Starting in 2015, the maximum payment cut for noncompliance will be 3.5 and 4 percent, increasing to a 9 percent reduction by 2019 that carries forward into 2023.

Nachimson agreed that “the absolute concern of costs to physicians is very real. ICD-10 is another piece that they are forced to take on at their own cost.”

Since ICD-10 implementation does not bring physicians any financial compensation, the AMA has recommended that the federal government find a way to offset the costs for physicians. This might mean, for example, offering tax credits or decreasing penalties associated with the other programs.

Implementation costs were, in fact, one area Rhonda Buckholz, vice president of ICD-10 training and education for the American Association of Coding Professionals (AACP), investigated during a member survey conducted in preparation for her NCVHS testimony. Among other things, she uncovered that costs for implementation were “significantly less than what we originally thought,” she said.

Buckholz told the Talk Ten Tuesdays audience that, on average, the total implementation cost (excluding staff time and the current delay) came out to $1,600 per provider. Total implementation costs averaged:

  • $750 per provider for small practices (under 10 providers)
  • $575 per provider for medium-sized practices (10 to 49 providers)
  • $3,500 per provider for larger practices (50 or more providers)

Another area of real concern for the AMA and others in the industry is Medicare’s decision to put off end-to-end testing until 2015. As Spector said, the AMA is “disappointed” by this decision and also is concerned that payers also are talking about delays.

“We need to do it now,” she said. “We know payors can’t test with every physician, but payers need to understand that until physicians have a chance to test with (them), they will remain skeptical about how smooth the transition will go.”

All of the guests on the broadcast echoed the AMA’s position. For example, the HBMA recommends that providers allow one year for end-to-end testing because, as Louie said, it is “mission-critical.”

“I really believe that if we conduct thorough, industry-wide end-to-end testing now — not at the last minute in 2015 — it will go a very long way toward assuaging fears and decreasing resistance in 2015. Without end-to-end testing, we aren’t ready, and that’s just the bottom line.”

Sidney Hebert, ICD-10 program manager for Humana Inc., gave testimony at NCVHS on behalf of America’s Health Insurance Plans (AHIP), which also considers end-to-end testing to be “absolutely critical.”

According to Hebert, most payers who participated in the recent WEDI summit had a “bit of an epiphany.”

“In order for us to get over the finish line for ICD-10, we must collaborate more tightly than we have been up to now,” he said. “Payers have been on their own path for provider readiness and testing and their own implementation plans, and they have been closely aligned in terms of their types of activities and basic approaches but they have been working on parallel channels.”

Collaboration Beyond the Norm

After acknowledging the credibility issue that exists and the significant perception of “deadline fatigue” that is so pervasive in the industry at the moment, Dr. Devin Jopp, WEDI’s president and chief executive officer, addressed several of the key components included in WEDI’s letter to the HHS secretary.

“Overall, our message was that the industry stands ready to help make this work, but we’re going to have to all take a collective breath together and do something differently,” said Dr. Jopp. “WEDI will lead through its workgroups.”

Part of the “differently” called for is improved transparency and better communication from the Medicare and Medicaid programs. For example, in regard to readiness testing, Jopp said, the industry needs to know “not only what is their plan but when will it happen and when will they share the results.”

In the letter, WEDI asked the Centers for Medicare & Medicaid Services (CMS) to conduct limited pilots and possibly provide funding for them since there are already a lot of trading partners ready to participate. The industry needs, for example, data about things like DRG shifts, not just anecdotes, Jopp said.

“We need to better coordinate our efforts and improve collaboration – and (to) collaborate to the level we haven’t seen in this industry before,” Jopp said.

 

Hear the Talk Ten Tuesdays broadcast of June 17, 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.
Janis Oppelt

Janis keeps the wheel of words rolling for Panacea®'s publishing division. Her roles include researching, writing, and editing newsletters, special reports, and articles for RACMonitor.com and ICD10Monitor.com; coordinating the compliance question of the week; and contributing to the annual book-update process. She has 20 years of experience in topics related to Medicare regulations and compliance.

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