September 21, 2015

Stanley Nachimson Receives Leadership Award

By

EDITOR’S NOTE: Stanley Nachimson, founder of Nachimson Advisors, LLC, is the recipient of the 2015 Ten Leadership Award from ICD10monitor. Nachimson was recognized for his decade-long industry leadership in the adoption of ICD-10. Nachimson is co-chair of the WEDI-SNIP ICD-10 Testing Workgroup. He has been co-chair of the HIMSS ICD-10 Task Force and currently serves as a member of the Healthcare Business Systems Committee. Previous Ten Leadership Award recipients have included Gloryanne Bryant, Linda Kloss, Mary Bessinger, and Beth Just, president and CEO of Just Associates.

 

He has always been “Stanley.” No matter how affable he appears to be, he is certainly not given to being called anything but “Stanley.” Not “Stan.” Or “Stan the Man.”

And talk to just about anyone in the healthcare industry on the phone, say you’ve been talking to Stanley, and the person on the other end of the line knows you’re talking about the Stanley. Send an email and mention his name, and everyone being copied knows it’s Stanley Nachimson.

But there was a time when Stanley was “Stan.” And that is when he worked at Carnegie Mellon’s radio station, WRCT, as the nightly newsreader and reporter, recording the network news and reporting college events. There at the college station he went by name of “Stan Roberts.” But it wasn’t the lure of broadcasting that held his fascination; it was mathematics, his subject major for which he earned a bachelor’s degree. He would go on to receive a master’s of science in applied statistics from George Washington University.

He later would find himself working in the federal government, specifically for the Centers for Medicare & Medicaid Services (CMS). He held various management, systems, and statistical positions at CMS and its predecessor agencies from 1974 onwards.

In 2000, he began working as the senior technical advisor in the CMS Office of E-Health Standards and Services, where he stayed until 2007. It was on his watch at CMS that the healthcare industry painfully migrated to the first required set of HIPAA standard transactions, ASC X12N’s version 4010A1 in 2003. Earlier, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) mandated that the healthcare industry use standard formats for electronic claims and claims-related transactions.

That 4010 adoption process was wrenchingly slow, as Nachimson remembers, but his experience in monitoring the transition take place would provide him with a historical perspective as the industry migrated to version 5010 nearly a decade later. In 2009, the U.S. Department of Health and Human Services (HHS) mandated the adoption of 5010 with its final rule that year. That was also when it was determined that 4010 would not support what was then the anticipated arrival of ICD-10. And at that point, Nachimson had formed Nachimson Advisors.

He quickly became a go-to person for perspective and analysis as healthcare once again found itself adopting to sweeping change.

As an industry consultant, Nachimson followed the 5010 adoption closely and was quoted frequently on the subject in the ICD10monitor e-newsletter, knowing that the transition from ICD-9 to ICD-10 would be fraught with peril — including delays, postponements, and legal challenges.

Nachimson also was called upon often for responses to controversial issues. He would be quick to offer both an acknowledgement of a problem while concurrently offering an admonishment — a one-two punch.

From 4010 to 5010

For example, back in December 2011, less than two weeks prior to the mandated implementation date of HIPAA Version 5010, the Medical Group Management Association (MGMA) was asking CMS for a six-month “contingency plan” allowing health plans to continue to accept 4010 transactions for a limited period of time.

Here was his first punch, an acknowledgement of this issue:

“The 90-day moratorium provides the type of relief that MGMA is asking for,” Nachimson said. “Providers should take these 90 days to complete system testing and (ensure) that they can transact business using the 5010 transactions. And they should be reminded that they (and health plans) are subject to CMS action if they do not comply.”

Then there was the second punch,  admonishing an industry resistant to change:

“This is disturbing, as the industry has been aware of the need to transition since the requirement was published in January 2009,” he said. “Many surveys over the past year indicated that the industry has been behind recommended timelines for meeting the compliance date.”

The theme continued with ICD-10:

“The reality of the situation is that we must get the industry on the new standards so that work can begin on ICD-10 implementation and other important efforts,” Nachimson said. “Further delays beyond the 90-day enforcement moratorium already granted by CMS will cause irreparable harm to ICD-10 and other improvement efforts.”

Delays Reported on the ICD-10 Transition

Nachimson always seemed to be optimistic. Here he is quoted in an ICD10monitor e-news, responding to the time when, in April 2011, CMS delayed the implementation of ICD-10 from October 2013 to October 2014:

“The industry should quickly determine what this delay means and how they can take advantage of it to assure that ICD-10 will be implemented properly on the new date. Hopefully we can coalesce around this new date and build a path towards implementation. I hope that once a new date is set, CMS will guarantee the industry that no more delays will be tolerated.”

Then, with 365 days before the updated compliance date of 2014, the ever-patient Nachimson wrote in the October 2013  edition of ICD10monitor e-news:

“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 revenues, 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.” 

The SGR Legislative Slip

And then the unexpected happened.

On March 31, 2014, the U.S. Senate passed H.R. 4302 to extend the sustainable growth rate (SGR). A provision for extending the ICD-10 delay for at least one year was tucked into an earlier House bill as a temporary measure the industry has come to call the “doc fix.”

Here is Stanley writing of the delay in the April 8, 2014 edition of ICD10monitor, in a piece titled The ICD-10 Delay – Why Did It Happen and What Do We Do Now?

“In an amazing political move, a sentence recently was inserted into a must-pass bill in Congress – the SGR patch – that delayed ICD-10 for at least another year,” he wrote. “It had nothing to do with the SGR. It was little-noticed and seldom mentioned. Too late; the ICD-10 proponents mobilized. The bill passed. And ICD-10 was again delayed!

Now, this may seem like a normal reaction to impending chaos, or a saving grace for the industry. But it was not seen that way by everyone. The industry panicked, CMS was confused, and organizations claimed that they wasted their investments. Despite the lack of progress, concerns about not being ready, or the true lack of justification, the industry said: woe is us.  

Frankly, how a rational person could have not expected a delay is beyond me. The industry was clearly not ready, was not adequately preparing to be ready, had not adequately projected what the impacts would be, and, in some ways, was preparing ways of getting around meeting the mandate. Virtually every signal within the industry’s control was flashing red. Instead of panicking, we should be giving thanks that we have this extra time.”

Then there was the latter half of his trademark one-two punch:

“The real question is this: What do we do now? If we repeat the behavior of the last four years, we of course will get the same result – rushing towards a deadline we are unlikely to meet, pitting organization against organization, and inviting further delays if not outright rejection of ICD-10,” he wrote. “We have to change the ways we plan, execute, test, and implement these major changes for plans, providers, clearinghouses, and vendors. We have to stop looking to CMS to tell us what to do and then basically not following or complaining about the instructions. We have to stop relying on CMS for every piece of education.”


 

Back on the Ten Track

Finally, a year later, in April 2015, the SGR issue came and went, with no additional delay of ICD-10. The Senate voted overwhelmingly, 92-8, for the $200 billion Medicare reform package, it ended the loathsome “doc fix,” and it also foreclosed any hopes by some for another ICD-10 delay.

Here is the list that Nachimson read on Talk Ten Tuesdays-Tuesday on the morning of April 21:

  1. There are no more excuses for not moving forward on ICD-10. Everyone needs to move now.
  2. For those that have delayed, there is not much time to do the necessary work for implementation. You must focus on the critical areas. For providers, those would be documentation improvement, system readiness, and testing.
  3. Providers must determine the best way to verify the accuracy of their documentation and coding. Suggestions would include having outside experts review the work, trading off with other providers to review each other’s work, or getting some computer-assisted tools to create documentation and coding.
  4. Health plans need to publish information on their policy changes due to ICD-10 and their testing and update schedules. There are a number of policy issues (e.g. when providers will start using ICD-10 codes on prior authorizations) that are still outstanding.
  5. Providers and plans should share their testing results, especially with those that will not have the opportunity to test. We have to understand what issues are out there that need to be resolved.

The Ten Truce

Then, back in July, CMS and the American Medical Association (AMA) issued a joint news release saying that CMS would not deny claims under the Part B physician fee schedule (PFS) as a result of ICD-10 coding errors for 12 months — a partial concession to the AMA, which wanted a two-year grace period.

Nachimson responded to the decade-long resistance by the AMA in a July 14 ICD10monitor article. When asked who blinked, either CMS or the AMA, Nachimson responded:

“There was give-and-take from both sides. CMS recognized that physicians may have some initial difficulty with ICD-10 coding, so they provided some transition relief. The AMA agreed to move forward on assisting providers with implementation in a strong manner.  Physicians will have to realize that they must use ICD-10 codes for services on and after Oct. 1, and those codes must be appropriate,” Nachimson said. “They (physicians) will have a little more time to get used to documenting and coding to the greatest specificity in ICD-10, but they still have to move towards that.” 

Nachimson is concerned, however, that physicians might take advantage of the 12-month transition period and use it as a delay tactic.

“I hope that they use it as a transition time and not think it is another postponement,” Nachimson said. “We will have to see.”

And so we shall.

 

 

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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