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What Now? WEDI Summit Tackles ICD-10
By Stanley Nachimson

In an attempt to provide direction both to the industry and the Centers for Medicare & Medicaid Services (CMS), the Workgroup for Electronic Data Interchange (WEDI) recently organized a gathering to respond to Congress’ surprise decision to delay ICD-10. The emergency summit featured both ICD-10 supporters, such as AHIMA and AAPC, and opponents, such as the American Medical Association (AMA), the Medical Group Management Association (MGMA), and the American Osteopathic Association (AOA), although the majority of attendees were from plan and provider organizations involved in ICD-10 implementations.

During the meeting, the industry recognized that it hasn’t been entirely successful in moving toward ICD-10’s original target date of October 1, 2014, with many entities, especially small providers, admitting they were in danger of not meeting the deadline. Also, it was agreed that little had been done to address the concerns of the AOA, the AMA, and the MGMA, which had objected strenuously to the timetable. In addition, the summit sought to determine ways to deal with the delay’s both unintended and intended consequences.

Discussion topics included a brief glimpse at ICD-10’s implementation history and implementation suggestions, including phased implementation by provider type (hospitals first, then physicians) and entity type (plans, then providers), and allowing voluntary adoption. Despite the lack of success thus far in achieving an overall implementation strategy, the majority of attendees continue to support a single ICD-10 implementation date for all entities.

Those who were ready to move ahead with implementation discussed their plans, while pointers were offered to organizations struggling with preparation. It generally was agreed that many more entities must perform testing to ensure a smooth transition. Several of the delay’s root causes were identified, including the following:

• No clear examples of ICD-10’s benefits were provided, especially as to how they applied to providers. There had been general discussions about improvements in public health, disease monitoring, biosurveillance, and payment accuracy, but these were only predictions. No significant pilot tests of ICD-10 implementation had been conducted.

• Education and tools should be made available at little or no cost to small providers to assist them in their implementations.

• Physician concerns about having less time for patient care due to increased documentation and coding weren’t properly alleviated.

• Many vendors’ revenue cycle management systems weren’t ready, even by April 1.

• Several payment groupers weren’t ready.

• Too much media coverage was devoted to strange ICD-10 codes, resulting in bad publicity.

• Several key organizations opposed ICD-10.

Many of the delay’s unintended consequences and resultant questions also were identified, including the following:

• There is a lack of faith that any new date will be adhered to and that further delays are likely.

• Many individuals who were adamant that the CMS wouldn’t change the date have lost credibility.

• Some payers now have postponed ICD-10 testing and training.

• Congress now is stuck in the middle of an industry initiative.

• Some workers’ compensation plans and state reporting requirements were switching to ICD-10 on October 1. What will they do now?

• Can providers and plans agree to perform dual coding on and after October 1?

• How will provider budgets be impacted?

• What will happen to coders already trained in ICD-10 who expected to start working on October 1?

• What will happen to scheduled training classes?

• What will happen to the code freeze?

The summit’s afternoon session focused on building a road map to move forward, no matter what the implementation date may turn out to be. In a spirited discussion, several themes were advanced, including the following:

 • Continue, enhance and expand, and standardize ICD-10 testing. Keep moving ahead with current testing plans and include testing coding accuracy.

• Develop and monitor vendor readiness.

• Provide incentives for providers to implement ICD-10.

• Educate Congress on ICD-10 and the impacts of further delays.

• Determine budget impacts.

• Develop an ICD-10 certification program for revenue cycle management vendors.

• Promote ICD-10’s benefits.

• Develop and monitor live pilot tests to help determine ICD-10’s real costs and benefits.

• Publicize actual testing approaches and results.

• Develop and enforce intermediate milestones.

• Develop confidence in a final implementation date.

• Understand and address the concerns of those not ready and those opposed to ICD-10.

• Provide more transparent readiness information for plans, providers, and vendors.

These steps will be summarized and an action plan will be developed and approved by the WEDI board, which hopes to provide final information to the CMS by the end of May.

— Stanley Nachimson is principal of the HIT consulting firm Nachimson Advisors and a For The Record editorial advisor.