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May 10, 2011

View of ICD-10 Implementation From the Top


“Insufficient documentation” has long been the battle cry of Medicare contractors conducting claim reviews—and a key challenge for the transition to a more comprehensive coding system was a theme echoed during the recent American Health Information Management Association’s (AHIMA) 2011 ICD-10 Summit that brought together more than 500 health information professionals, providers, payers, and vendors came together in Baltimore in mid-April.


The simple fact of the matter is that documentation, as it is currently provided by clinicians, will not make full use of the new code set. Without comprehensive documentation, coders won’t have enough data to record the new codes to their fullest extent, according to a summary in the Journal of AHIMA(1).


As Ann Watt, MBA, RHIA, the Joint Commission’s associate director, department of quality measurement, said, “There is a tremendous educational challenge in terms of physicians documenting practices and making sure they understand the level of specificity needed in the record.”


Other presentations, discussions, and overheard conversations revealed several key areas of concern, which are briefly summarized below.


Digging for the Details

Expectedly, system inventories have been at the top of everyone’s to-do list, and summit attendees have begun to identify databases, systems’ applications, and interfaces that currently use ICD-9 codes and, subsequently, will need to be switched to ICD-10. Many expressed surprise at “how deeply the ICD code set had worked its way into the enterprise’s operations.”


For example, Linda Martin, MA, PMP, Banner’s information technology project management senior consultant, said, “This kept me up at night as we were uncovering more areas that were affected. It was just mind-boggling.” To get control, Banner developed a spreadsheet listing all applications, interfaces, and report extracts across all business units.


Delivering Specific Documentation


On this point, discussion revolved around how the electronic health record (EHR) system might help with that challenge “by triggering documentation alerts for clinicians, reminding them that the new code set requires additional specificity, such as the severity level…” Many attendees left the summit realizing that they needed to contact their software vendors about the EHR and its capacity to nudge clinicians toward providing more comprehensive data.


Coding Consensus


It’s too soon for coding professionals to begin in-depth training on the new code sets since implementation is still more than two years away. However, HIM professionals agree that coders may begin to work with more specific documentation.



(1)American Health Information Management Association, “ICD-10 in 2011: A Report from the AHIMA 2011 ICD-10 Summit,” Journal of AHIMA, April 27, 2011, http://journal.ahima.org/icdsummit



For example, managers could begin to introduce the concepts, code structures and conventions behind ICD-10 and evaluate the extent of staff knowledge of anatomy and physiology. Depending on the size of a facility, managers may want to begin to create training plans covering inpatient and outpatient coding for all skill levels and learning styles.


Planning for a Big Budget

There’s no easy way to say it: The transition to ICD-10 will cost, for some larger organizations, millions of dollars. Smaller facilities and offices will, of course, get by spending a lot less.


Dave Biel, MS, a principal at Deloitte Consulting, reported that budgets for the transition and post-implementation auditing tasks for the company’s clients averaged $25 to $30 million for three years, depending on the size and complexity of the organization. Intermountain Healthcare’s current estimate comes in at $20 million with 40 percent going toward capital costs and 60 percent toward operational expenses.


Juggling the Priorities


Implementation of ICD-10 is just one of many priorities facing the healthcare industry. As AHIMA reports, “The convergence of regulatory requirements in the coming three years is unprecedented: HITECH and the meaningful use program, the HIPAA 5010 standard, the ICD-10 transition, healthcare reform, accountable care organizations, and intensified pay-for-performance initiatives.”


Needless to say, complying with all of these requirements is stretching resources in more ways than just financially. Attendees shared war stories about lack of time and staff to do the jobs that need to be done and conflicts about what tasks should take priority.


Initially, industry representatives believed that the transition would focus on IT and/or coding issues but they’ve learned differently. Those now in the trenches of implementation realize that ICD-10 is an integral part of everything they do, affecting people, departments, and functions throughout their organizations. For example, ICD-10 is a reimbursement issue, a quality initiative, and a business-driven initiative.


George Alex of the Advisory Board Company agrees, saying, “We thought this was an HIM problem and would contain mainly HIM issues. That was far from the truth. It is really a multidisciplinary effort,” requiring collaboration.



“Providers, payers, and vendors are all in this together,” said Dennis Winkler of Blue Cross Blue Shield of Michigan. “It is important for us all to figure it out so that on October 1, 2013, we don’t go bump in the night.”


For more resources on ICD-10 planning and preparation, visit AHIMA’s website at



About the Author

Carol Spencer, RHIA, CHDA, CCS, is a senior consultant with Medical Learning, Inc. (MedLearn®) in St. Paul, Minn. She brings more than 20 years of experience in health information management, coding, teaching, data quality and revenue integrity. She is an accomplished local, regional, and national speaker and author covering topics such as recovery audit contractors (RACs), payment audits, MS-DRG reimbursement systems, ICD-9-CM coding, and is an AHIMA-approved ICD-10-CM/PCS Trainer. Ms. Spencer is a thought-leader in data analytics and an expert on compliance in coding, query, and clinical documentation improvement strategies.

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