October 17, 2011

Kick-starting the ICD-10 Transition Process


How the heck do we begin?

Develop a project charter! Create a communication strategy template! Perform a GAP analysis! Distribute readiness surveys! List critical success factors! Draft a project management team! Schedule meetings!

For those beginning the ICD-10 transition process, taking that all-important first step seems to be the most difficult part. There is so much information out there about what needs to be done and when it needs to occur. Practices feel overwhelmed trying to sift through the many implementation strategies, action items and potential starting points. And, frankly, there exists quite a bit of misinformation and conflicting advice.

From the numerous workshops and national surveys we’ve conducted, we found good news in that the country seems to have turned the corner as it pertains to ICD-10 awareness. Most practices now understand that the ICD-10 transition is inevitable and that it most likely represents the biggest challenge in more than 20 years to how healthcare providers conduct business. The bad news is that many practices, especially small- to medium-sized practices, have no idea even how to begin the transition process. But these practices won’t need to feel resigned to failure if they can just find a way to take that first step. Here’s an easy way to do it.

Impact Analysis

Performing an ICD-10 impact analysis is a great way to kick-start implementation. Grab a notebook and take a stroll through your practice. Everywhere a diagnosis code touches the workflow, make a note. This will be an eye-opening experience for those who still feel that ICD-10 is just an IT or coding issue. There will be some obvious areas of impact, such as the superbill, but there will be many processes for which ICD-10’s future effects will not be so apparent. As you note each area of impact, keep in mind three types of issues that need to be addressed: human (Is training required? If so, how much?), technological (Software or hardware upgrades?), and budget requirements (What is this going to cost?)

As you walk the halls, this also is the perfect time to converse with any member of the staff who is affected by diagnosis codes (and by extension ICD-10-CM). At the same time, miniature training conversations inevitably will occur, and this can start getting your folks realizing that ICD-10 is coming, ICD-10 is different, and adjustments may have to be made to their day-to-day work processes.

As a road map for you to consider, here are some areas and processes that will be impacted by the ICD-10-CM transition.

Documentation Impact

This is an excellent place to start the formal ICD-10 conversation with your providers. Does current documentation, both written and in EMR template form, allow the most specific ICD-10-CM codes to be chosen? If not, procedures or services may be deemed medically unnecessary.


With ICD-10 containing five times as many codes as its predecessor, and greater specificity required, many practices are rethinking their commitment to superbills. Obviously, if you decide to continue using them, superbills must be updated for the new codes. Any department in your practice that uses superbills for reference (billing, coding, etc.) must have updated versions and also must be trained on how to use the new tools.

Order Entry/Requests (Lab, X-ray, PT, OT, DME)

You need a diagnosis code in order to describe what you need tested or filmed. Therefore, paper and electronic requests need to be updated in order to indicate the proper ICD-10 codes and not the old ICD-9 codes. Additionally, ICD-10 training will need to be conducted for any staff members who submit lab or radiography (X-ray, MRI, CAT, etc.) orders. This most likely will include back-office staff.

Home Health Treatment Plans Impact

If your practice prescribes a home treatment plan, you know that most of these plans are updated infrequently. If such a plan is created before the ICD-10 transition, it most likely will contain ICD-9-CM codes and therefore must be addressed once the transition occurs.

Referrals to Outside Providers

Referrals to outside providers for second opinions or specialty consideration must be updated to accommodate ICD-10 codes. You will be doing your referred providers a disservice if you continue to use ICD-9-CM codes to describe conditions for which you are seeking assistance. Likewise, the return “consultative report” must be in sync with the new code set.


In many cases a diagnosis code must be submitted as part of a prescription. This process will require an ICD-10-CM upgrade in order for pharmacies to be able to service these prescriptions (ePrescribe can help!)

Administrative Services: Insurance Pre-authorization and Surgery Scheduling

In most cases, a diagnosis code will be required in order for an insurance company to approve a desired surgery, diagnostic test, etc. In order for patients to receive the medical care they need, your insurance pre-authorization must be updated to accommodate ICD-10-CM. Both the actual request and the person submitting that request will need to be able to speak the ICD-10 language.

Denied Claims Follow-up Impact

ICD-10 represents an opportunity for insurance payers to deny your claims. Expect this to happen even if you transition perfectly. Do not allow insurance companies to take advantage of the chaos caused by the transition. Follow up on your claims denials aggressively. Beefing up your claims monitoring and appeal processes will reap great benefits when claims are denied due to reasons associated with ICD-10. The top payers (Blue Cross, Cigna, United, etc.) already have announced that they have created their own version of an ICD-9-to-ICD-10 crosswalk. Do you trust them? Do you think they are translating ICD-9 to ICD-10 equitably, or do you think they are building crosswalks that will not establish medical necessity and therefore give them the ability to deny your claims? Looking for a defense? Get a copy of GEMs and don’t let them translate your ICD-9 codes to ICD-10 codes that will not justify medical necessity.

Performance Measure Reporting Impact

Internal (clinic-specific) and external (PQRI) reports that require diagnoses codes will need to be updated for ICD-10. This process can be as generic as reporting your top 25 diagnoses in more extensive “outcomes” reports.

Retrospective Reporting Impact

Many key management reports used by your administrators are based on diagnosis codes. Starting Oct. 1, 2013, year-to-date diagnosis benchmarks based on ICD-10 being compared to the previous year’s reports based on ICD-9 may become an apples-to-oranges comparison. The impact on reporting requires that diagnoses codes be translated in order to be of any value.

Payer and Business Partner Impact

Some of your smaller insurance plans either may delay the transition to ICD-10 past Oct. 1, 2013, or they may not make the transition at all. Also remember that auto insurance and workers’ compensation plans are not subject to the HIPAA mandate and are not required to transition to ICD-10. Insurance plans that delay the transition or do not transition at all will create a substantial rippling effect on your practice. Business partners such as billing companies and clearinghouses also must make the move to ICD-10. If you use a small billing company that may be financially unable to make the change, they may not be able to submit your claims under the new system.

Staff Training Impact

Aside from possible practice management and EMR software and hardware upgrades, staff training will be your most expensive line item during the ICD-10 transition. The impact on budgeting and your bottom line will be significant. Every member of your staff who deals with diagnosis codes must be trained depending on the extent they work with them.

Budget and Productivity Impact

Budgeting for the ICD-10 transition must be given a high priority. Expendable training dollars must be allocated carefully depending on the size and needs of a practice. At a recent ICD-10 boot camp, one of the top coders in the country relayed the following:

“Under ICD-9, I can currently code between 20 and 25 charts an hour. Under ICD-10, my best efforts resulted in only being able to code between eight and 10 charts an hour.”

A decrease in productivity occurs naturally whenever staff trains using new processes. Several variables will impact productivity during the transition. Ensuring staff commitment and quality of training coupled with making adjustments to workflow in a proactive and timely manner will help mitigate this impact.

v.5010 Impact

This impact is negligible and transparent if you and your IT vendor are working together to implement and test changes. There exists serious potential impact if this upgrade is overlooked.

Practice Management Software and Hardware Impact

The impact on this vital area may involve a substantial financial commitment depending on whether your vendor is paying for an upgrade or your practice is required to shoulder the cost. During the initial transition to ICD-10, and for those payers that will continue to use ICD-9 codes, your software will be required to run both coding systems simultaneously. This will put a strain on server and workstation hardware capacity.

Coding Staff, Resources and Tools Impact

The impact on coding staff will be significant. Twenty-year habits need to be changed and an entire new coding language needs to be learned. Coding resources such as software encoders and books need to be updated and training needs to occur in order to allow for coding under the new system. EMR templates also will need to be changed. Most importantly, coding staff will need to code both ICD-9 and ICD-10 during both the training and transition phases.

Performing a simple impact analysis that examines every area in your practice influenced by diagnosis codes is an excellent way to begin the ICD-10 conversation. Likewise, it is the perfect place to start your implementation plan. The timeliness of this activity is critical.

Do it soon. Do it now.

You’ll be glad you did.

About the Author

Dennis Flint is director of consulting and educational services for Complete Medical Solutions. Dennis formerly served as the CEO of a large, multi-specialty physician group, a full service MSO and was a certified professional coder through AAPC. He has authored or co-authored numerous “common sense” practice management books and implementation manuals. Educated at the United States Air Force Academy, he had a distinguished career as an Air Force pilot flying numerous secret and sensitive missions.

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Read 1 times Updated on September 23, 2013
Denny Flint

Denny is the chief executive officer of Complete Practice Resources, a healthcare education, consulting, and software company headquartered in Slidell, Louisiana. He formerly served as the CEO of a large, multi-specialty physician group, full service MSO. Denny has authored or co-authored numerous “common sense” practice management books and implementation manuals. He is an award winning, nationally known consultant, speaker, and educator bringing his expertise to making the complex “simple.” He currently serves on the editorial board of ICD10 Monitor. Educated at the United States Air Force Academy, Denny had a distinguished career as an Air Force pilot and has a long history of commitment to excellence and dedication to his clients’ success.