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Updated on: March 17, 2016

One Year and Counting: ICD-10 Implementation Progress Varies

Original story posted on: November 14, 2013

Just as the political divide in Congress between Republicans and Democrats became evident at the stroke of midnight with  the partial shut down of the federal government, so too does the divide swell between providers in large metropolitan areas and those located in rural communities as both face the mandatory compliance date for ICD-10 implementation coming one year from today.


For on Oct. 1, 2014, as mandated by law, HIPAA-covered entities must be ICD-10-compliant. So, where do providers and payers stand in terms of their readiness to meet the deadline?

Ready or Not?

A number of association surveys conducted within the last 90 days seem to reveal an industry that appears unlikely to be ready a year from now. The oft-cited survey by the Medical Group Management Association (MGMA) conducted last June in particular painted a picture of an industry (mainly physician practices) that has been slow to adopt the new coding system. According to the survey, only 4.8 percent of responding practices reported making “significant progress” in assessing their readiness.


On the facility side, Precyse, a major health information management (HIM) vendor, reports a modestly more positive picture of ICD-10 readiness.

“Precyse conducted an informal poll last month about physician and staff preparedness for ICD-10,” Tom Ormondroyd, a vice president of the company, said in a written statement to ICD10monitor. “The vast majority of our respondents felt good about their preparation, and their education is well underway. However, more than 20 percent are worried, behind, or haven't even started yet.”

“My concern is that the majority of the industry is behind,” noted Maria T. Bounos, a registered nurse and the practice lead for coding and reimbursement products 
for Wolters Kluwer Law & Business.

Readiness Varies by Size, Geography

“With a year left to go, in regards to readiness our provider clients are across the board,” reported John Wollman, executive vice president of HighPoint Solutions. “ We’re finding (predictably) the larger provider organizations are close to ready for trading partner testing, and the smaller provider organizations are behind and don’t seem to be progressing fast enough to catch up.”

Representative of what Wollman certainly would consider a “larger provider” is CHE Trinity Health, which seems to be well on its way to becoming compliant by Oct. 1, 2014.

Last May, Trinity Health and Catholic Health East announced the consolidation of their two operations, creating what many in the industry believe to be one of the largest Catholic health systems in the country – it’s now known as CHE Trinity Health.

“CHE Trinity Health has developed a comprehensive plan to address the people, process, and technology components of this broad-scale change,” wrote Tauana McDonald, a vice president at system’s Newtown Square, Penn. location. “We are on track with our plan, but like most other large healthcare organizations, we need every day remaining between now and the Oct. 1, 2014 transition date to get ready.”

Illustrative of the aforementioned red/blue, rural/urban divide is the reaction from Brock Slaybach, vice president of the National Rural Hospital Association.

When asked if his association members were falling behind or on track with the Oct. 1, 2014 deadline, Slaybach acknowledged that rural providers are “struggling with a myriad of pressures that are constraining their resources, both in time and money.”

“Rural providers feel like they’re drinking from a fire hose of change,” said Slaybach, who, in offering advice to rural hospitals that are not on track at this time, reminds them of the importance of having a transition plan.

Slaybach said that many are behind due to time and budget constraints.

Indicative of the implementation challenges being faced by small, rural hospitals is the situation confronting Kimber Wraalstad, administrator of the Cook County North Shore Hospital and Care Center in Grand Marais, Minn., 80 miles south of the Canadian border. Wraalstad has two individuals working on the implementation — her director of health information and a coder.



“Both my director of health information, Teresa Hanson, and our coder, Kathy Bernier, are looking at this transition as both an opportunity and a challenge,” Wraalstand said. “They both have been attending various classes (offered by the College of St. Scholastica and the American Health Information Management Association, or AHIMA) to prepare themselves for transition.”

Although both women consider implementation an exciting opportunity, according to Wraalstand, she admits that both of them are concerned about their software system.

“This is another transition for providers who are still somewhat overwhelmed and shell-shocked from our adoption of the electronic medical record,” Wraalstand said.

Rural hospitals aren’t alone when it comes to implementing ICD-10.

“Other types of institutional providers (home health agencies, nursing homes, etc.) may be at a greater risk,” Stanley Nachimsom said, principal of Nachimson Advisors.”   “Physician practices, in my opinion, are still behind where they need to be.”

Size Does Matter

Meanwhile, in California, home of one of nation’s largest healthcare information management associations, Gloryanne Bryant serves as national director of coding quality, education, systems, and support for Kaiser Foundation Health Plan, Inc. and Hospitals. Bryant is also the immediate past president of the California Health Information Association, and she reports that most association members appear to be on their way to being ready.

“I believe that most health information management (and) coding members here in California are on their way to being ready – that's not to say there isn't much to do still,” Bryant said. “During the final year, there will be the actual ICD-10 code set education and training and allocation for ‘practicing the coding.’”

Bryant, an AHIMA-approved ICD-10-CM/PCS trainer, explained that having enough time to practice coding is necessary. She also alluded to the issue of the much-discussed coder shortage.

“Having time allocated for practicing the coding of ICD-10 will be very important,” Bryant said. “Arranging for coding coverage will be important while employees are in education/training and practice. This is a challenging area since we have national shortages of credentials and experienced coding staff.”

The Crunch: End-to-End Testing

End-to-end testing among providers and trading partners has been another well-documented issue, particularly because completing testing has been estimated to take as long as 12 months.

“Many (providers) should be in the midst of testing right now,” Bounos said. “In reality, many are in the midst of assessment and planning.”

In addressing time and cost considerations, the Lott QA Group created what it calls “The National Testing Platform for ICD-10.” According to the company, the platform is a “collaborative, work-and-social, asynchronous, end-to-end testing environment for external testing.” The platform coordinates testing schedules, allowing users to process 837 and 835 transaction sets.

“The majority of our provider clients are on track in planning for their internal and external testing,” reported Juliet Santos, the firm’s executive vice president. “Many are ahead of schedule and have already been working on their internal testing and remediation, and are now preparing to be part of the National Testing Platform for ICD-10 as part of their external testing strategy.”

For all hospitals not on track with their ICD-10 preparations, regardless of whether they are located in a rural or urban setting, working with vendors is a recommendation of Santos.



Follow the Money

The financial impact of the transition to ICD-10 is never far from the mind of Gregory M. Adams, a former chief financial officer of a New Jersey hospital and past chair of the Healthcare Finance Management Association (HFMA).

“For those just beginning, it’s critical that they understand the financial impact of the ICD-10 transition – but it is as, if not more, important to assess their internal IT systems to ensure they are all modified to handle the transition,” Adams, currently the president of the clinical consulting division at Panacea Healthcare Solutions, wrote in an email to ICD10monitor. “In addition, hospitals need to ensure all of their external vendors and payers are also prepared. If not, even the well-prepared hospitals will see significant impacts on billings, receivables, and cash flow.”

Advice at the Ready

With exactly 365 days remaining, here is some advice for those still lagging behind the eight ball.


“First, recognize that the date is solid and that revenue is at great risk if you are not ready.  Work closely with your vendors to get the necessary upgrades, and focus today on identifying the key documentation challenges you will be facing - what are your highest revenue, greatest volume codes, and what are the ICD-10 changes around them.  Look to your health plans and associations for assistance on ICD-10 implementation.”


“It is critical to work with … vendors to reassess project timelines, remove barriers to timely implementation as much as possible, and identify project risk mitigation strategies ASAP. Identifying the appropriate resources that can help them fast track their internal preparation is key, as well as identifying what it would take to protect their bottom line.”


“For organizations that are just getting started with their implementation, don’t panic. Instead, identify those areas with greatest revenue impact and focus your efforts there. Also, a comprehensive contingency plan to deal with potential cash flow bottlenecks is a good idea.”


“Begin by understanding your HIT system’s migration plan for ICD-10 coding. Obtain transition planning templates from trusted sources – many are available online – and sit down with your health information management (HIM) director and begin to map out interventions required by next year’s implementation. Seek the involvement of … executives and caution them not to overlook their physicians.”


“My recommendation for those behind the eight ball is to focus on the specialty areas most impacted by ICD-10. You can fast-track your analysis of specialty areas through a financial impact analysis. The analysis looks at your top DRGs by major diagnostic category and can help focus your efforts as the implementation date quickly approaches.”




“(It’s) time to regroup if you are not on track. Look at the key deliverables needed to be ready for implementation; secure funding and resources. Resources may come from external suppliers and vendors. Bring in project management to help if possible; (this) can be a benefit. ICD-10 will need to be a top priority in the coming 12 months, so having support for the needs of readiness and implementation (must) be in place in order to be successful.”


“Our advice to laggards is to start now on contingency plans from a people, process, and technology perspective. Do not wait until a month before go-live to try to come up with a strategy. As painful as it may be, it’s better to own up to being late now and figure out the most cost- and resource-effective approach to implement in case you ultimately aren’t ready in time and there is no movement in the mandated date.”


“Education must expand beyond coders and CDIS immediately and move to all populations as we move into 2014. Our forward-thinking clients are using their interdepartmental ICD-10 steering committees to ensure their project plans are on target. They are also implementing clinical documentation improvement (CDI) programs, coding audits and dual-coding programs, (plus) ramping up their focused education and training efforts, identifying the remaining ‘less obvious’ populations who need education, and significantly increasing communication efforts to across their organizations on the importance of preparing for ICD-10.”

The Final Word

In her small yet essential critical-access hospital, again, 80 miles south of Canada, a country whose adoption of ICD-10 is frequently cited, Wraalstad waxes philosophically.

“As with our other transitions, we will make it through this by continuing to work together,” she said.

Let’s hope so.

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.
Chuck Buck

Chuck Buck is the publisher of ICD10monitor and is the executive producer and program host of Talk Ten Tuesdays.

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