It has been a very bumpy ride since early April, when ICD-10 was delayed once again. Ironically, I was in the U.S. Virgin Islands when I received the news, training physician groups in St. Croix and St. Thomas. The training I was conducting centered on documentation for ICD-10 as part of the groups’ clinical documentation improvement (CDI) programs. Even with the sudden delay in ICD-10, the physicians on both islands remained positive and very anxious to stay on course. 

 

When I returned to the U.S., I found mixed reactions from my clients. One of my larger hospital systems just stopped everything in the way of ICD-10 preparations, much to my dismay; another slowed down, but the others breathed a sigh of relief that we have more time to do things right operationally in order to move toward successful implementation. Would these hospitals and physician groups I have been working with meet the compliance deadline of Oct. 1, 2014 if the delay had not occurred? Absolutely, they would have, as we all have been working nonstop to make certain that we could. However, many operational improvements in project plans would have taken a back seat until after ICD-10 went live. Now, we have additional time to put these improvements into action and take steps such as development or improvement of CDI programs, providing more education and support to physicians looking to improve their documentation, and working on enhancement to areas such as centralized scheduling, accounts receivable analysis, workflows and templates, etc. If any organization stops the implementation process now and waits until next year to restart, efforts may be lost, which will be costly, to say the least.

I see many problems cropping up with this delay, which is somewhat frightening. Keep in mind, as I have said many times, preparation and proper ICD-10 implementation will improve operations and potentially improve compliance and reimbursement. But waiting until the last minute can destroy a healthcare organization.

If you think about it, whether reimbursement is derived from a MS-DRG, a payment rate, or a CPT/HCPCS code, without accurate coding, medical necessity cannot be supported, nor can quality of care – which impacts any organization, whether a hospital, long-term care facility, physician practice, or otherwise. What I am seeing now is that many physicians and healthcare organizations are thinking “ICD-10 will never happen, so why use the resources?” Others think ICD-10 will be delayed again and again until we move to ICD-11.

There is so much speculation in the industry now, it seems that very few believe it will happen on Oct. 1, 2015, even though we have the deadline date in the Inpatient Prospective Payment System (IPPS) proposed rule. I must be honest: I was beginning to feel some skepticism myself, but then as I thought about the reasons we are moving to ICD-10, I realized that this is our only option, given that we are running out of ICD-9 codes and dealing with outdated data. ICD-10 does have its benefits, and switching over to it makes sense, considering the specificity it offers.

Most of my hospitals are about 65 percent ready to “go live” with ICD-10, and most are staying the course. As I mentioned earlier, I have one hospital system has stopped the preparation process, which I believe will cost the organization more money. I have one hospital that is ready to go with the exception of performing end-to-end testing.

I must say, the Centers for Medicare & Medicaid Services (CMS) cancelling the testing this year created another stir of skepticism in the healthcare industry, not to mention suspicion that CMS does not have confidence we will ever move to ICD-10. One of the issues we really need to stress to all payers is that we need in-depth end-to-end testing to ensure that risk is reduced. From talking to providers and physicians, I get the sense that the real fear is not getting claims to insurance carriers, not getting paid, dealing with delays in reimbursement, and addressing reductions in productivity, which will impact bottom lines.  Most are not afraid to make improvements and changes operationally, or to improve documentation, which many agree is necessary to support performance measures and quality of care.

What happens if your organization waits and does nothing until this time next year? What if we do transition to ICD-10 on Oct. 1, 2015? Where will you be? Will you be able to continue operations? Do you really want to take that risk? I am amazed that even before the delay was finalized, a number of physicians, physician groups, and even hospital systems had not even started getting ready for ICD-10. I do understand that meaningful use stage 2 is important, but so is ICD-10. My advice to all is to continue along the proper course, and don’t stop moving toward ICD-10 compliance. We all know that clinical documentation is one of our biggest challenges, and it will take time for practitioners to adjust their documentation to meet the requirements of ICD-10.So, here are my recommended steps:

  • If you have not begun getting ready for ICD-10, do it now. It is not just about software/hardware updates and coding. If you need help, hire an experienced ICD-10 expert.
  • If you have been working on the ICD-10 project, do not stop.
  • Take a good look at your project plan and make timeline and milestone adjustments to either expand the scope of the plan or just to give you some breathing room for the additional time.
  • Keep working with practitioners on clinical documentation improvement.
  • Review your training plan and make necessary modifications. The more training you can give the coders, billers, practitioners, and other staff, the better prepared you will be.
  • Review all workflows and templates and make improvements to the electronic health record (EHR) templates
  • If you do not have a clinical documentation improvement program in place, implement one now.
  • Measure productivity now until we “go live” with ICD-10. If you don’t have a productivity standard, develop one.
  • Contact all your payors and get on their schedules for testing.

Keep your steering committee active and meeting on a monthly basis at a minimum.

Above all, don’t stop moving forward. Stay the course.

 

Deborah Grider, CPC, CPC-H, CPC-I, CPC-P, CPMA, CEMC, CCS-P, CDIP, Certified Clinical Documentation Improvement Practitioner

Deborah Grider has 34 years of industry experience and a recognized national speaker, consultant and American Medical Association Author who has been working with ICD-10 since 1990 and is the author or Preparing for ICD-10, Making the Transition Manageable, Principles of ICD-10 and the ICD-10 Workbook, Medical Record Auditor, and Coding with Modifiers for the AMA.  She is a senior healthcare consultant with Karen Zupko & Associates.  Deborah is also the 2017 American Health Information Management Literacy Legacy Award Recipient. She is a member of the ICD10monitor editorial board and a popular panelist on Talk Ten Tuesdays.