By Summer Humphreys, Executive Consultant, Advisory Services, Beacon Partners
Twitter: @BeaconPartners
Now that Congress has rejected requests to delay ICD-10, it’s time to get on the bandwagon or risk significant financial implications. ICD-10 touches virtually every aspect of your organization’s processes and systems, and failure to prepare and comply with the mandate will have a significant impact on your reimbursements.
If your organization has lost momentum or has not started the ICD-10 journey, hiring internal resources or working with external experts will be necessary to meet the deadline. Below is a cheat sheet – based on best practices and industry guidelines – of essential questions to ask leadership and next steps:
- Is ICD-10 a priority for your leadership team?
Evaluate organizational awareness of ICD-10 and confirm leadership is in place to drive the transition. Successful ICD-10 planning involves defining project leadership, executive sponsorship, and reporting structures. Given the far-reaching organizational impacts of ICD-10, without defined roles and responsibilities, a critical remediation area may be missed. Identify stakeholder accountability for ICD-10 compliance and designate project managers to lead revenue cycle, coding and clinical documentation improvement (CDI), and IT system initiatives. Develop a project communication plan that sets expectations about what should be communicated to whom, the reason for the communication, frequency, and method. - Are your systems ready and have you evaluated the impact of ICD-10 to all system workflows?
Assess operational readiness by taking an enterprise-wide systems and process inventory to identify where codes are used. Utilize assigned project managers to uncover all systems and processes where ICD-9 codes are sent, received, or stored. Conduct workflow analyses to ensure understanding of how systems and processes are impacted. This exercise can provide immediate benefit to an organization as workflows operating inefficiently are identified. Develop a prioritized project plan and remediation timeline for each impacted area. For example, technology and workflows need to be optimized within patient access to assure compliant orders for dates of service on or after October 1, 2015. Conduct regular reporting on initiatives and ensure stakeholders are being held accountable for designated tasks. - Does your staff have appropriate organizational awareness and knowledge of ICD-10?
Understand what roles individuals play within your organization with respect to ICD-9 code usage, and employ a role-based training initiative. While coders, CDI specialists, and providers will need the majority of training, areas, such as patient access, ancillary departments, business offices, and IT should not be overlooked. Also, keep in mind the impact on your quality team. Patient populations monitored by core measures, as well as other quality metrics are determined by ICD-9 codes. When selecting a training vendor, confirm the vendor offers courses tailored by job function and provides the necessary courses for coders and specialty-specific training for providers. Track and communicate training progress and ensure training compliance is an organizational priority. As part of your strategy, attempt to incorporate training with other planned education to reduce workflow disruption. - Are you establishing ongoing experience with the new code set?
Act fast to incorporate dual coding initiatives. Based on experiences with ICD-10 in other countries, research suggests that allowing coders to simultaneously code in ICD-9 and ICD-10 allows them to achieve proficiency and decrease productivity loss. Dual coding has been shown to significantly reduce the anticipated 40 to 60 percent inpatient and estimated 20 percent outpatient productivity loss. The first step is to create a project plan that identifies coders, checks systems, and determines expected coding system upgrades. Next, create a strategy for managing dual coded data to be analyzed. A coding roundtable of key stakeholders from an organization’s coding team should be developed to create accountability and drive documentation improvements during the dual coding process. As part of the learning process, coder education should initially emphasize documentation requirements for coding the most common conditions within the organization and those with the highest allowed amounts. A minimum of six months of practice is recommended. - Are you conducting internal and external testing of systems for ICD-10 compliance?
Define testing goals and document a plan to test each impacted system internally and conduct external testing to the greatest extent possible. Appropriately testing impacted applications is a complex and time-consuming process and should not be seen as a last step. Many variables — including competing organizational priorities and resource availability — as well as clearinghouse, payer, and third-party tester schedules, can influence the testing timeline. Designate a well-defined team to undertake, define, and monitor the testing readiness plan for your impacted systems and software. Each impacted system should be reviewed for the type of testing that is needed. Billing systems are the most complex and must be ready to send ICD-10 coded bills to payers or payment will be denied. Testing of billing systems should include all of the workflows where codes live, (e.g., claim edits that currently contain ICD-9 codes). Use your high volume and high value codes for testing, and determine the ICD-10 workflow for each impacted application. Then, complete individual testing of applications by running the applications through the identified workflows. Once that process is complete, begin integrated testing through following the process for codes to flow to downstream applications and out to the payer. If you haven’t been selected for payer testing, then work with your clearinghouse to test claims externally through them. - Is your CDI program optimized and ready for ICD-10?
Emphasize clinical documentation process improvements to realize bottom-line gains now while preparing for ICD-10. While most healthcare systems have a CDI program, many are not achieving the desired results in appropriately coding conditions to the highest level of specificity. For example, if the organization is not able to code the specific type of congestive heart failure in ICD-9, the problem will only worsen in ICD-10 with requirements for greater specificity to attain complications and co-morbidities (CCs) and major complications and co-morbidities (MCCs) for many DRGs. While revamping a CDI program is a separate goal, perfecting ICD-9 queries and introducing ICD-10 queries early will help prepare an organization for ensuring compliance with the increased specificity ICD-10 demands. - Have you planned for predicted delays in cash flow?
Create a contingency plan to mitigate potential productivity and revenue losses. Hope for the best, but prepare for the worst. Based on Canada’s ICD-10 experience, coding productivity may drop by 50 percent immediately following implementation. Performance improvements may take at least 90 days to be realized. If claims are suspended, rejected, or delayed following ICD-10 implementation, have a plan available in advance to quickly respond to different scenarios. Alternatively, some providers and payers have drafted stopgap provisions in their contracts to maintain a consistent cash flow and “true up” every three months.
While changing processes, systems, technologies, and staff resources to accommodate the shift from ICD-9’s 17,000 to ICD-10’s 140,000 codes may seem overwhelming, there is still time to meet the requirements by taking a prioritized and focused approach. Having the right mix of expertise and staffing is necessary to meet the upcoming deadline. Contingency plans will also help mitigate losses following ICD-10 implementation. Beyond getting paid, ICD-10 also promises to improve clinical outcomes by increasing the specificity and accuracy of clinical documentation to guide patient care decision-making. It’s an investment that is worth the effort.
About the Author: Summer Humphreys is an experienced healthcare professional with more than ten years of work in healthcare consulting, hospital operations, and ambulatory care. She has advised hospital and physician leadership in a wide variety of areas including strategic planning, operations, hospital-physician alignment, mergers, and acquisitions. This article was originally published on Beacon Partners Blog and is republished here with permission.