Will Your Outpatient Physician Orders Be Compliant by the ICD-10 Deadline?

By Yvonne Dawdy, RHIA, MSW, Executive Consultant, Advisory Services, Beacon Partners
Twitter: @BeaconPartners

Imagine waking up on October 1, 2015 to thousands of non-compliant outpatient physician orders simply because they do not contain an ICD-10 code, are still using ICD-9 codes, or involve a handwritten diagnosis with no associated code. Unfortunately, this is a challenge that many healthcare organizations will encounter after the ICD-10 deadline if action is not taken immediately.

Despite the best preparation efforts, healthcare organizations can expect electronic and handwritten non-compliant orders from physicians. Based on my work supporting clients through the ICD-10 transition, up to 50 percent of a health system’s outpatient physician orders may be non-compliant. The often overlooked problem will translate into claims denials and increased A/R days. The result: potential multi-million dollar payment backlogs for many healthcare organizations. The good news is that there are steps organizations can take now to reduce follow-up remediation efforts. To mitigate delays in registration, coding, billing, and reimbursement, start by asking the following questions about processes that will be affected by non-compliant orders:

• Will it be acceptable to pre-certify a patient prior to October 1, 2015 for services after the deadline?
• Will systems be tested and updated to accommodate ICD-9 and ICD-10 codes prior to October 1, 2015?
• Will electronic orders placed before October 1, 2015 for services after October 1, 2015 need to be updated?
• How will you handle recurring patients? Will they need to be discharged and re-entered for services after October 1, 2015?

Once your key stakeholders reach consensus on answers to these questions, develop a plan and take immediate action. Below are strategies that should be included in your plan:

• Conduct a gap analysis of outpatient electronic and manual order volumes and processes. Identifying software systems and processes that will be impacted is essential to prioritize and define areas of remediation. Along with automating processes, it is important to ensure electronic ordering systems have the capability to provide ICD-10 codes for orders that are placed prior to October 1, 2015, but are for services performed after October 1, 2015. In addition, review inventory order forms and update those that contain ICD-9 codes.
• Ensure patient access and electronic ordering teams have well-developed ICD-10 workflows and processes. Aligning familiar workflows with IT systems can mitigate productivity losses by reducing the time for teams to transition to new processes.
• Create an outreach plan and tools for physicians that use manual ordering processes. Organizations can support community physicians who will continue to use manual rather than electronic ordering processes by providing resources, including tip sheets and connecting them to industry tools, such as CMS’ Road to 10.
• Develop an internal and external communication plan for physicians, practice managers, and patient access team members. Examples of communication initiatives include using the frontline patient access team to provide information and resources to community physicians. You can also create training sessions for practice managers to communicate the importance of compliant orders and introduce them to tools to assist them with the transition. Keep in mind that different messaging will need to be customized for offices that use system-wide electronic medical records and those that use manual processes.
• Drive accountability and measure progress using existing ICD-10 governance structures. Targeted remediation and enhancements can be made by monitoring order compliance metrics after implementation. While governance structures can help ensure that employed physician groups are accountable for changes, they can also provide guidance and support to physician groups that are not employed by the health system.

Avoid wasting millions of dollars in remediation, follow-up effort, and costly payment slowdowns by executing a plan to manage non-compliant outpatient physician orders now. To make it to the October 2015 finish line, healthcare organizations should consider resource and expertise support to ensure a successful transition.

This article was originally published on Beacon Partners Blog and is republished here with permission.