Updated on: March 14, 2016

Planning, and Doing: Making ICD-10 Implementation Successful

Original story posted on: February 2, 2015

Now that the New Year is here, we’re certainly counting down the months to the scheduled October 2015 implementation of ICD-10. Your ICD-10 implementation plan must include education and training. This is key to your success with the new code set. It takes education, learning and building of knowledge, training, and the practice of coding to have a complete plan. In addition to education and training within your plan, you must include system changes, testing, change management, and payor readiness. Systems preparedness is a major component to any good implementation plan. But the question is: How are you really doing? Is your planning going to result in success? Are you fearful of failure?


To answer these questions, let’s first look back. The timeline for ICD-10 has not been short. Rather, it has been a long journey of many years. Back in 1996-1998, informal and formal testing of ICD-10-PCS was conducted with ICD-10. For example:

  • As an informal test, in October 1996, a total of 70 health information professionals were trained in the use of ICD-10-PCS. After the training, they coded a sample of records from their institutions using ICD-10-PCS and reported suggestions and problems to the ICD-10-PCS project staff.
  • The Centers for Medicare & Medicaid Services (CMS) conducted a formal test of ICD-10-PCS in order to determine if it would be a practical replacement for ICD-9-CM. CMS used two clinical data abstraction centers (CDACs) to do so: DynKePRO in York, Pa., and FMAS in Columbia, Md.
  • As part of a contract awarded in 1994, a primary task of the CDACs was to collect clinical data from approximately 1.5 million medical records over a period of five years. The primary end product of the CDAC contracts was the development of accurate and reliable clinical data in quantities sufficient to support analytical efforts associated with the Health Care Quality Improvement Program. Since the CDACs had a ready supply of current medical records and extensive experience in reviewing, abstracting, and coding medical records, they were selected to test ICD-10-PCS.

Ten years went by, with dialogue and debate of the pros and cons of ICD-10. The Medical Specialty Societies joined in as participants in the content development of ICD-10-CM in the meantime. In 1999 we began to use ICD-10-CM in the U.S. for mortality reporting (death certificates). In 2003 there was formal testing of the code set by the AHA (American Hospital Association) and the AHIMA (American Health Information Management Association) for both hospital and physician settings. In 2006 there was testimony given before the U.S. House of Representatives Ways and Means Committee supporting and opposing the adoption of ICD-10. In August 2008 the proposed rule with the implementation date of 2011 was issued. Many comments were provided and the industry was heard. The implementation timeline needed to be five years, thus the final rule came out in January 2009 with the implementation date of October 2013, allowing for five years of preparation.

Back in 2012, a letter from the AMA (American Medical Association) to HHS (the U.S. Department of Health and Human Services) was submitted asking for a two-year delay of implementation. Other requests to extend the implementation date were also submitted resulting in a one-year delay, moving the implementation to October 2014. Subsequently, this past year, in March 2014, the AMA and a few others again asked for another delay – and as we all know, this was approved via the Protecting Access to Medicare Act, which moved the implementation date to October 2015. Now we’re hearing rumors that the AMA and a small group of others once again want yet another delay, this time two more years.

These continual delays can cause providers to lose the sense of urgency to prepare, which may be the situation for some in specific healthcare settings in particular.  For those who need time for planning and implementing, there appears to have been many years of opportunity in which to accomplish this. But fear not: there is help available across the healthcare industry to help those who have not prepared.

Often there are good plans established, but execution is not always optimal, which can result in the plans not being effective. Therefore, it is important to review your ICD-10 implementation plan details and timeline now. Determine if the tasks in your plans have been completed. Key preparation activities should include the assessment of current physician documentation patterns and your current ICD-9-CM coding accuracy; the analysis of current operational processes; thorough review of the staffing requirements and systems impacted; and a close look at the determination of the financial impact of this transition. In addition, hospitals should conduct a review of MS-DRG shifts associated with the ICD-10 code set and perform a documentation and coding assessment. Keep in mind that there are many free resources available to everyone, including physicians. Obtain tools and resources on implementation planning and timelines that are available on the Internet or through links on the cms.gov website. Increased awareness of the resources to keep planning properly is the answer for being prepared for the implementation of ICD-10. Complacency about planning is not the proper position to take. 

For some, planning for ICD-10 may appear to be onerous, a dreaded necessity with time commitments associated with organizing, coordinating , and completing various tasks. But again, remember that there are numerous resources available to help facilitate these tasks. We have the AMA offering educational programs and seminars to support physician practices preparing for implementation of ICD-10. The AAPC (American Academy of Professional Coders) has a large volume of coding and documentation resources, several available for free. Both CMS and AHIMA have strategically developed and offered a wide range of tools, resources, advice, and collaboration. These resources should help remove any doubt and/or concern of not being prepared. 

Additionally, testing systems and participating in CMS national testing should be strongly considered. Following the November 2014 national testing, CMS reported that it had accepted 76 percent of all national ICD-10 test samples during the ICD-10 acknowledgement testing week. There were more than 500 providers, suppliers, billing companies, and clearinghouses that participated in the tests.

Now is the time for those who are fully engaged in the implementation process to collaborate with those who might be struggling with planning or even fearful of the process. Being successful with planning for ICD-10 requires more than just reading one or two articles about ICD-10. We all need to obtain and utilize resources, and to become catalysts for change and improvement. No doubt there are particular needs for documentation improvement, which are no different than what we need now. There are HIM (health information management) and CDI (clinical documentation improvement) professionals available to assist and guide you through the process of addressing concerns of being inadequately prepared for ICD-10. Avoid procrastination and remain positive. Remember the model for quality improvement: plan, do, study, and act (PDSA).

Along with reaching out for assistance when necessary, keeping this in mind will ensure that we’ll all be successful in supporting the ultimate goal of achieving improved healthcare for everyone. No more delays!

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.
Gloryanne Bryant, RHIA, CDIP, CCS, CCDS, AHIMA-Approved ICD-10-CM/PCS Trainer

Gloryanne Bryant is an independent health information management (HIM) coding compliance consultant with more than 40 years of experience in the field. She appears on Talk Ten Tuesdays on a regular basis and is a member of the ICD10monitor editorial board.