October 20, 2014

October 2015 ICD-10 Compliance Date: What, Me Worry?

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During the first quarter of 2014, health systems worked very diligently to meet the Oct. 1, 2014 ICD-10 deadline. The level of preparedness among providers varied from high to low. In early spring, however, the compliance date was moved to Oct. 1, 2015, and the response from the healthcare industry varied – the question was to move forward as planned, or  to slow down or stop the preparations? 

Now that summer is behind us, many providers are still unconcerned about ICD10 compliance – some may be thinking that hey, the compliance date is still far away, next year, and they don’t need to worry about it just yet. But with the fall of 2014 having arrived, the dynamics have changed:

  • The economy is improving and unemployment is decreasing;
  • Employees are moving around companies/organizations seeking better opportunities;
  • The Centers for Medicare & Medicaid Services (CMS) announced that it would be pushing the compliance date for Meaningful Use Stage 2 to 2016; and
  • Interest rates are low, and the forecast is that they will increase in 2015.

During this past summer, again, many healthcare organizations either continued working on ICD-10 as planned (still shooting for the October 2014 goal) or slowed down or stopped their projects. Many organizations had reductions in force (employees and/or consultants) and very few implemented a knowledge management system to preserve all the work they had done.

As we approach the fourth quarter of 2014, virtually every healthcare organization will be approaching a truly mandatory planning period. There will be planning for the organization, financial/budgeting planning, human resources planning, IT planning, etc., and many organizations will be establishing their goals for 2015. But how can we plan when there are intangibles in the equation (if the compliance dates are moved again)?

Currently CMS and other industry groups are stating firmly that eventually, in 2015, perhaps, the ICD-10 compliance date will be here, and all other compliance dates will not be pushed back any further.

So as we approach 2015, the planning for all compliance, ICD-10 included, should start at the C-level and the program level and then be coordinated. As we plan, there are areas of concern at the different C-level functions/positions. They are:

CFO: Preparing the budget for 2015 to include the compliance programs, payer contracts, hiring of new employees, and outsourcing (consultants) at a higher rate. There should have been a contingency plan built in as well, just in case a payer is not ready for ICD-10.

CIO: The goal is to go beyond current issues in implementing an electronic medical record (EMR).  This would include other installs, implementations, and needs to look further on down the road, deep into 2015 (meeting the ICD-10 compliance date, solidifying operations post-ICD-10, Meaningful Use, etc.). This involves the immediate addressing of resources issues – money, human resources, and time constraints – and finding a perfect mix to meet the organizational needs. The CIO needs to plan in order to determine how the organization is going to meet the compliance deadline.

CEO: The CEO needs to lay down a vision as to what the organization needs to look like following implementation of ICD-10. The aim is to determine whether to simply meet the compliance date or to use the compliance date as a mechanism for opportunities.

During 2014, many organizations had ICD-10 projects approved and funded. Due to the delay, funds and resources were reallocated, and the progress to date was not tracked. This is the time to reexamine the current ICD-10 project plan and make changes.

It is widely accepted that ICD-10 preparations are risky and unique (in the U.S., this is the first time ICD-10 is being implemented, though other countries have implemented already and the informal report card indicates that it has been marginally to moderately successful).

Every organization has its own unique way of project management, but the plan should cover the following aspects (based on the changing dynamics):

Table 1 – (A practical guide to Earned Value Project Management – Charles I. Budd, Charlene S. Budd, page 5)

Outcomes/ Action

Scope

Schedule

Budget

Plan

Deliverables

Due dates

Costs allocated

Progress

Are all necessary tasks completed?

How long did it take to complete the work accomplished?

How much did we spend on the work reported as finished?

Projection

Will all requirements/ specifications be met?

When will the project be completed?

What is the estimated total cost at completion?

Contingency (if any )

 

 

 

Having a project plan that is a work-in-progress lets the project manager truly understand the current situation, how to change the situation, and how to adapt dynamically to a new set of circumstances.

Working from the plan and working with the C-level executives will enable them to make appropriate planning decisions for 2015. The C-level executives do not want to risk embarrassment via failures resulting from non-compliance. If they feel the pressure, it won’t be long before the project manager will feel the heat.

With 12 months to go before the ICD-10 compliance date and three months to go before 2015, the mantra should be “plan your work and work your plan.” Providing an initial plan and subsequent updates will help C-Level executives stick to their plans, alter their plans, and make better decisions for the organization.

As former President Eisenhower said:

“In planning for battle, plans are useless, but planning is indispensable.”

About the Author:

Paresh K. Shah is president of MindLeaf Technologies, Inc., and a member of HIMSS –ICD-10 Taskforce as well as the co-chair for HIMSS Playbook.

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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.
Paresh K. Shah

Paresh K. Shah is president of MindLeaf Technologies, Inc., and a member of HIMSS –ICD-10 Taskforce as well as the co-chair for HIMSS Playbook.