During the past few weeks I have spent time revising project plan timelines and milestones to give organizations more to prepare for ICD-10 – which in most cases is very much needed. All the physicians I have spoken to since the latest delay was announced are indicating that they are just going to wait until next year, but why is that? Hasn’t everyone in the industry received an explanation regarding the importance of preparing for ICD-10? We all know that documentation is going to be one of the most significant challenges, beginning and ending with the physician, but that is not the only challenge. It will take a great deal of effort, support, and time to get documentation the specificity we will need, not only for ICD-10, but to meet the standards of compliance for coding and billing claims. It is a well-known fact that current documentation is not sufficient to code to the specificity ICD-10 will demand, so much work needs to be done.

 

On May 22 one of my physician groups forwarded me a blog posting titled “What Practices Should Do about ICD-10: Forget About it.” This posting went on to suggest that other regulatory issues are more important. What is more important than ensuring continued revenue to support the practice? This post also indicated that physician preparations can wait until next year, because the electronic medical record (EMR) generally chooses diagnosis codes (or they are dictated by the superbill). This post also went on to note that physicians and coders will need to understand ICD-10 – but not for another year.

As a former practice administrator, I understand the challenges associated with running a medical practice quite well. I agree that coders will need to understand ICD-10 (and so will physicians), but I believe it will take more time than just a few months to change documentation patterns. Also, there is more to the ICD-10 implementation process than simply learning the coding and updating software. ICD-10 will affect every area of the medical office, including:

  • Coding
  • Billing
  • Front office
  • Clinical (MAs and nursing)
  • Physicians
  • Other ancillary areas of the practice

Think about how the advance beneficiary notification (ABN) is executed in the medical practice. I would venture to guess that at least 70 percent of medical practices today fail to execute a valid ABN. Would it not be beneficial for the MA or nurse who typically gets it signed to learn the importance of the diagnosis, given that medical necessity is the most common reason a procedure or service is not covered under Medicare?

What about taking a look at how MAs are utilized in the medical practice? Would present circumstances not offer a good opportunity to teach the MAs how to document in ICD-10? Should we maybe even provide them some coding training so they can help the physicians?

Taking this a step further, what about the large practices that have separate coding and billing departments? It is time to perform an accounts receivable analysis to determine how much money your practice might be losing because of denials initiated due to lack of medical necessity. You might be surprised, as it might be more than you might think.

Now let’s talk about the electronic health record (EHR). I know that most EHR vendors have upgraded or are in the process of upgrading systems for ICD-10. But you also must consider the workflows and templates in the EHR. Most vendors are not updating their templates. Who is going to review and rebuild all the templates and workflow mechanisms that need to be updated for ICD-10? What about the practices that just adopted an EHR and are still using the templates that came with the system? Are the templates compliant for the specialty? Are they difficult to use? Do the templates or macros that physicians are using encourage cloning? What about the diagnosis code pick lists? Do you think physicians will scroll down to find the most specific codes, or just pick the first one? How can we make it easier for the physician to select a more specific code using the electronic tools we have? I ran across a cardiology practice that was entering the same information into four software applications – is this efficient? They were unable to interface any of the applications, so the solution was to find applications that would help them become more efficient. This is another project that takes time.

The superbill has been outdated for years. Actually, the superbill was developed in the early 1980s to give to patients to allow them to file their own claims. Will a physician use a seven-page superbill? I don’t think they would. I know I would not. So shouldn’t we start looking for electronic options? It will take some time to research all the options and make a decision.

What about clinical documentation improvement initiatives? I know hospitals are diligently creating clinical documentation improvement programs and processes, but shouldn’t physician practices start adopting the same initiatives? I realize that many hospitals have great software programs to assist them, and that some physician practices either cannot afford them or they don’t fit practice needs. But clinical documentation improvement (CDI) goes hand in hand with clear and concise documentation. CDI means more than just performing an audit once a year. It is a process of monitoring documentation, querying for clarity, and providing education to make improvements. A medical practice cannot buy a CDI program in a box and expect it to work well for them. A CDI program needs to be customized to the practice, by specialty, and its operations. As part of preparation, a baseline ICD-10 readiness audit should be conducted. Once that is completed, the practice will be able to realize where the most serious documentation deficiencies are. From this point, the physicians should be educated on how to document their most common diagnoses using ICD-10. It should not stop there, as the physicians will need reinforcement, continuous auditing and monitoring, and additional education. If you wait until next year to begin this process, you will struggle to meet the deadline. This should be started now.

These are just a few of the implementation tasks that must be accomplished in the medical practice arena prior to the implementation of ICD-10. Yes, coding training can wait another year. But there is still much to do. So my advice to physicians is to make sure you pay attention, get started analyzing practice deficiencies, make sure your documentation is reviewed for compliance, and learn how to document for ICD-10. If you forget about it and do nothing, your entire practice will be negatively affected. If you are not sure where to begin, hire a consultant with the appropriate expertise in ICD-10 before it is too late.

Deborah Grider, CPC, CPC-H, CPC-I, CPC-P, CPMA, CEMC, CCS-P, CDIP, Certified Clinical Documentation Improvement Practitioner

Deborah Grider has 34 years of industry experience and a recognized national speaker, consultant and American Medical Association Author who has been working with ICD-10 since 1990 and is the author or Preparing for ICD-10, Making the Transition Manageable, Principles of ICD-10 and the ICD-10 Workbook, Medical Record Auditor, and Coding with Modifiers for the AMA.  She is a senior healthcare consultant with Karen Zupko & Associates.  Deborah is also the 2017 American Health Information Management Literacy Legacy Award Recipient. She is a member of the ICD10monitor editorial board and a popular panelist on Talk Ten Tuesdays.