March 29, 2010

ICD-10 Timetable — Where Do You Stand?
By Lindsey Getz
For The Record
Vol. 22 No. 6 P. 20

Experts agree that planning for the seismic shift in coding operations should be well under way.

While October 1, 2013, may seem like another lifetime, the truth is if healthcare organizations haven’t started planning for ICD-10 implementation, then they’re already behind. There is definitely a false sense of timing, says Rhonda Buckholtz, CPC, CPMA, CPC-I, CGSC, CPEDC, COBGC, CENTC, vice president of business and member development for the American Academy of Professional Coders. “The year 2013 may seem like a long time away and [as a result], organizations are making the mistake of not dedicating the time necessary now to properly implement and plan,” she says.

Rick Kneipper, chief administrative officer and cofounder of PHNS, agrees: “Most hospital execs that I’ve asked where they stand with ICD-10 implementation have given me a blank look and expressed that ‘it’s not until 2013, so I don’t have to worry about it.’ Somewhere along the way people have gotten the wrong impression. While it’s true that full implementation is not until 2013, there is a first-time deadline for anyone that uses or submits claims electronically to show first level of 5010 compliance by the end of this year. So if you’re not already working on it, you’re behind.”

Industry Preparedness
By this time, an assessment of what needs to be done should already be in the works. “Healthcare organizations should be performing their assessments now so that they can properly plan their implementation approach,” says Deborah Westervelt, managing director at ViPS, a General Dynamics IT company. “A comprehensive assessment will help healthcare organizations determine the best approach for implementation.”

Simply performing an ICD-10 assessment is a huge task in itself. A thorough assessment is an exercise designed to help the healthcare organization build a strategy to achieve compliance that should involve identifying all organizational components that will be impacted by the conversion and then gauging the readiness to address transition for each component, says Patricia A. Zenner, RN, healthcare management consultant at Milliman, Inc, an actuarial firm that recently released a report measuring industry perceptions and readiness for ICD-10. The report details how organizations should currently be focused on synthesizing the output of the planning phase. “We recommend that organizations use a four-phase approach to ICD-10 implementation: planning, preparation, implementation, and postimplementation,” explains Zenner. “Upon completion of the planning phase, organizations should have a strategic approach document that brings together all pieces of the assessment and integrates them into an outline of what is impacted, preferred approaches through transition, contract and vendor strategies/changes, the resources needed, recommendations on how communication of the organization’s approach should be relayed internally and externally, and how education should be rolled out through implementation.”

According to Zenner, organizations that are on track with the report’s recommended timeline should already be well into that planning phase, targeting completion in the first quarter of this year. That includes completing an assessment examining all facets of the organization. “Since ICD-10 has the potential to affect nearly every aspect of the organization, the assessment should cover every aspect as well,” Zenner says. “It’s better to err on the side of covering too much rather than risk omitting something important. Once all of the components have been identified, then the organization can develop detailed strategies and tactics for achieving compliance. Those strategies and tactics feed into the detailed implementation plan that must ultimately be developed and used.”

A comprehensive assessment should have at least three major components, the first two being business and technical, Westervelt says. “The ICD-10 business impacts are far-reaching, touching upon virtually all functional areas of provider and payer organizations,” she adds. “While the technical impacts should not be minimized, the business impacts should drive the technical approach to implementation.”

The third component on Westervelt’s list is a data assessment, meaning that providers should consider ICD-10’s impact by analyzing current ICD-9 data. She suggests organizations ask questions such as these: What are the concentrations of ICD-9 codes? What are the highest volumes and highest dollar ICD-9 codes?

“Once the current data is analyzed, an ICD-10 simulation can help to predict how those current ICD-9 codes will be dispersed in ICD-10,” Westervelt says. “This simulation can provide guidance into areas of concern, policy and contract updates needed, risk adjustments, training needs, and so on.”

Training will be a key component of the process, making it wise to plan for those needs now, says Marge Klasa, DC, ARNP, Bc, medical director for Context4 Healthcare, Inc. “The coding system hasn’t been changed in 30 years, so this is going to be new for everyone,” she says. “It’s a big change, so it is important for everyone to start training or at least plan for training now. Will it be Web based? Classroom based? There is a lot to learn. For providers, they will now have to write completed documentation that drills down into the various levels of medical conditions. For diabetes alone, there are about 230 codes with ICD-10. Though it will require extensive training, the benefit is reduced coding errors and fewer denials. You will have fewer claims returned because of less chance of error and fraud.”

Klasa adds that the change to ICD-10 will “open up the world of coding,” since everyone will need retraining—including payers. “Coders should jump at the opportunity to be consultants to the payers as they update their EDI [electronic data interchange] mapping and implement ICD-10 into their policies,” she continues. “This is a huge effort, but it’s going to be a great thing for coders.”

Why the Holdup?
Considering it’s such a huge task, why haven’t more organizations begun preparing for ICD-10? One theory is that many providers seem to believe Health and Human Services will push back the implementation deadline, giving them more time to make changes. After all, the original compliance date was published as October 2011, though the final rule mandated October 2013. But it’s dangerous to bet on a change in date. Even if it is pushed back, the amount of work involved in implementation still means starting now is a wise decision. “Get in the mindset that this is going to happen,” stresses Klasa. “It’s time to get moving.”

Some haven’t begun planning because they don’t realize the full scope of change involved. “I would urge that people begin to understand that a change to ICD-10 is extraordinarily complex,” says Kneipper. “This is not just a plug-and-play situation. We’re not just going to 150,000 different codes, but we’re also changing to an alpha-numeric system. That means changing not only the software but, in many cases, the hardware, too. And it affects any application in the hospital that currently touches ICD-9 code. That could be in accounting, reporting systems, and many more places. For some hospitals, it could affect hundreds of applications, so it’s not just about coding.”

However, part of the problem may also be that in an effort to prioritize, ICD-10 did not make it to the top of the to-do list for some organizations. “There are too many other major initiatives going on right now,” notes Westervelt. “Health IT, HITECH Act, EHR incentives, and the possibility of healthcare reform to name only a few. Many of these are in the near term while the ICD-10 compliance date may appear to be in the distance. It may be difficult to commit the resources right now.”

Furthermore, the idea that vendors are solely responsible for ICD-10 implementation is also a problem that’s causing delay. In reality, vendors are only one piece of the puzzle. “The only person that can prepare and assure readiness in your practice is you,” Buckholtz says. “While you might find some support in the vendor marketplace, they cannot do it all.”

Westervelt adds that those who are under the false impression that vendors are responsible for implementation may be focusing on only one component: the technical implementation. “Akin to Y2K, these organizations are looking at the implementation as solely technical and not looking at the big picture and realizing the impacts are on all areas of the healthcare business, from the patient’s encounter with the provider, through recording the encounter and billing, to the payer receiving and validating the codes and performing all other necessary business functions through payment to final disposition,” she says.

That’s not to say the vendor has no role. “The technical aspects of implementation may be addressed by vendors for their specific products, but those implementations must be in concert with the business processes,” says Westervelt. “The healthcare organization must also plan for testing of all updated software, both internally and with trading partners.”

The changes that need to be made cannot all be done by vendors, agrees Klasa. “Your coders need to be up-to-date and able to meet the challenges of ICD-10,” she says. “This is not solely a vendor issue. Vendors are not coders; they’re engineers and they take their cue from coders. Hospitals need to rely on their HIM team to move into the ICD-10 environment, and part of that is making sure vendors are 5010 and ICD-10 compliant. If they’re not, it’s the hospitals that will be held accountable and they will be given fines if they don’t comply.”

Robert B. Burleigh, CHBME, a member and former chair of the Healthcare Billing and Management Ethics and Compliance Committee and president of Brandywine Healthcare Services, adds that the vendor community must play a significant role in implementation but agrees that this fact alone does not get hospitals and other practices off the hook from being held accountable. “Because the majority of hospitals use commercial software, there are certain changes that the vendor must be responsible to make; the institutions simply couldn’t do it all themselves,” he says. “However, it is the hospitals’ responsibility to ensure their vendors are not only making those changes but that they are made on time. Make sure they are testing now and on schedule to be sure that everything is going to work. In other words, hospitals are responsible for ensuring their vendors know the importance of this change and are going to come through.”

If a provider is uncertain about the reliability of its vendor’s promises, it may be time to move on, Burleigh says. “You need to make the decision whether or not to bet on your vendor now,” he says. “If you decide they aren’t reliable or aren’t on schedule to be ready in time, then you need to move on and do so pretty quickly. However, while there may be some vendors who are unprepared, the majority of them have a vested interest in being ready and will be testing well in advance. Vendor support is one area I’m not too concerned about.”

Communicating the urgency of ICD-10 to C-level executives may also be a reason for delay. “Admittedly, it can be difficult to communicate the urgency,” says Zenner. “But one of the best ways to get executives’ attention is to appeal to their individual interests. For example, the CFO [chief financial officer] is concerned about expenses and revenue. Make a case for how early planning and careful preparation can impact both.”

Catching Up
Healthcare organizations that find they are behind in planning should make an immediate effort to catch up. According to Zenner, first and foremost, the effort should be on the assessment process. “If a hospital hasn’t done an impact assessment, they need to start there. They can’t know what they need to do or how long it’s going to take until they take that first step,” she says.

If the assessment has been completed and hospitals know what they need to do but find themselves behind in their timeline, Zenner says to prioritize. “We recommend they focus on what they need to do first and what can wait,” she says. “For example, because of the potential long lead times and complexity, they should put vendor and payer contract negotiations as a high priority.”

Don’t panic too much if you’re behind; just plan to get started now. “It’s never too late to start planning,” says Westervelt, who believes the real key to a successful implementation is obtaining C-level support. As a matter of fact, getting that commitment from hospital executives—who need to realize that ICD-10 is a business challenge that requires support from across the organization—should be one of the first steps, she adds.

Fortunately, many organizations are recognizing the importance of getting started. “Since the beginning of 2010, both payers and providers seem to be more interested in starting their ICD-10 planning,” Zenner says. “We are hearing a lot of our clients acknowledge that they are late getting started and are now ready to begin. Perhaps the advent of 2010 has made some procrastinators realize they really do need to get started, though we also have clients telling us they are not prepared to discuss ICD-10 but think they will be ready in a few months. At least for right now, our perception is that provider preparedness is all over the place but moving in the right direction.”

— Lindsey Getz is a freelance writer based in Royersford, Pa.