September 21, 2015

The ICD-10 Coding Final Countdown Checklist, Coding Policies & Procedures: Part 3 of a Four-Part Series

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We are now within two weeks before ICD-10 implementation begins on Oct. 1, 2015. Going through your readiness checklist is a daily process, and at this point we all must ensure that there is nothing forgotten or skipped. The ICD-10 countdown checklist should include several key activities and areas, including but not limited to the following:

 

  • End-to-end testing                    
  • Systems and IT
  • Education and training                       
  • Communications
  • Physician/provider awareness and engagement
  • Coding assessment and dual coding         
  • Documentation assessment               
  • Policies and procedures   
  • Physician queries
  • Patient financial services readiness   
  • Denial management
  • Clinical documentation Improvement
  • Contingency planning      

Another important readiness area for the coding and health information management (HIM) arenas is coding policies and procedures, or P&P. This area generally is one that should be at the forefront within your department, organization, and/or practice, with checks made annually or bi-annually. Within the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) Compliance Program Guidance for Hospitals is the subject of having written policies and procedures to support your employees, but also to ensure that compliance is being achieved.

Updating policies and procedures requires time to read through what is currently written and in place, to determine if it all is still accurate and applicable, and to check where changes and revisions to the wording or language within the P&P are needed. Gather up your policies and make a list, or create an inventory of them. Depending on the size of your department, you could take the approach where each manager is assigned certain P&Ps to review and update; in other words, share the work.

If a policy or procedure has ICD-9-CM wording/language or codes contained within it, this certainly will be one to review and update.

Some specific coding policies and procedures may include:

  • Coding productivity standards
  • Coding quality standards and expectations
  • Coding staff annual continuing education requirements
  • Coding vendor quality and productivity requirements
  • Physician query P&P
  • Coding workflow P&P

You also may have in place some very specific ICD-9-CM coding policies, similar to the list below:

  • Coding of external causes
  • Coding personal history status
  • Coding family history status
  • Coding BMI
  • Coding malnutrition
  • Coding complications
  • Coding long-term drug/medication use 

Once the P&Ps are ready they will need to be disseminated to your staff to ensure their understanding and compliance. Include in your staff meetings a review of the changes to the P&Ps. You may want to have staff initial or sign off to acknowledge that they have read and understand the policies. Keep track of when and with whom you reviewed the policy changes.

Take a look at your ICD-10 coding readiness checklist and be sure coding policies and procedures are listed. See the simple example below to give you a visual of how the P&P checklist could look.

List the title or number of your policy, include a column to indicate the topic or subject of the Policy, add the date policy was last reviewed, indicate whether there were codes or languagerelated to the ICD-9-CM code set contained within the policy, and include columns for the dates of the different steps as well as the new or revised language or wording that is recommended for the policy/procedure form. Also, do not forget that ICD- 10 has two code sets, ICD-10-CM for diagnosis and ICD-10-PCS for the procedure coding system; thus your policies should be worded correctly.

Next week, in the final article of this series, we’ll discuss coding job descriptions and hiring assessments as a component of your ICD-10 coding readiness checklist.

 

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

Gloryanne is a coding and HIM professional with 35 years of experience. She is the past president of the California Health Information Association. Gloryanne is a member of the ICD10monitor editor board and is a popular guest on Talk Ten Tuesdays.

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