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The U.S. Department of Health and Human Services (HHS) announcement regarding the possible delay of the ICD-10 implementation date has caused great uncertainty in the industry. It’s truly overwhelming for most, as “Delay, or no delay?” is the question many have asked and grappled with during the last month. The gut reaction for most providers during previous periods of uncertainty such as this has been to take a break, reprioritize and move on to the next regulation that needs to be dealt with, especially if the regulation is tied to penalties. This reaction is a patently human response that may make sense to someone who doesn’t realize that ICD-10 is one of the biggest enterprise-wide changes to the industry in the modern era. It’s a change that takes time to understand, particularly in terms of how it affects your organization’s ability to plan, implement and evaluate solutions. Now is clearly not the time to step aside, take a breather from the inevitable and go on to the next regulation.

Hypothetically, if a delay was announced, it would affect each sector of the industry differently. Whether you are affiliated with a vendor, institution, physician practice, educator, consultant or payer, a delay could mean lost jobs, affecting employment, possibly inducing bankruptcy or eliminating any opportunity to get “caught up.” For some, it could mean complete devastation, while to others it could be a blessing in disguise.

Whether or not a delay is announced, a prudent recommendation is to maintain your momentum if you are in the midst of analysis – and if you have not started, get started now! This article is a synopsis of an ICD-10 whitepaper Wolters Kluwer Law and Business wrote, a piece urging organizations to act now, regardless of implementation date.

ICD-10 requires organization-wide change management simply because it is a change that involves every aspect of an organization, with the possible exception of housekeeping. ICD-10 is not just a coding issue; it is a concept that involves assessment of, and implementation planning for, clinical documentation improvement (CDI), education, reimbursement impact, payer relations, information systems and vendor readiness. The change management potentially will involve both internal and external resources. It is time to think holistically and to get out of your silos, as well as a time for understanding that this process is fluid and may require tweaking along the way.

ICD-10 assessment and implementation planning involves the following:

  • CDI – The adoption of improved clinical documentation is not new for healthcare professionals, as it is one of the most basic concepts manyclinicians learn on day one – specifically, “if you didn’t document it, you didn’t do it.” This phrase speaks volumes as it pertains to ICD-10, specifically because improved and complete documentation will render improved coding and accurate data for optimal reimbursement. 

  • Education – Understanding how ICD-10 will affect you and your institution is extremely important at every professional level. Coder and clinician education is a critical part of the assessment and implementation process, but not all-encompassing.  If you keep in mind that all training should be job- and role-specific, perform assessments based on where gaps are identified, and remain transparent and resolute, you will have a successful ICD-10 educational program.

  • Reimbursement – Take the time to understand your business and perform an impact analysis at your facility. An impact analysis will help you understand how you are performing under ICD-9 as well as help you understand the projected impact of ICD-10. Throughout this process you will learn which service lines are winners and losers, but more importantly, delay or no delay, your business deserves a thorough review and analysis to ensure optimal reimbursement. 

  • Payer Relations – Take inventory of your payer contracts, as “negotiation time” is now. Specifically, take a moment to reflect on this statement: there will be no one stopping the commercial payers from going live with ICD-10 on Oct. 1, 2013.

  • Information Systems – Turn over every system and interface so you can better understand your internal IT systems. Assess whether external systems, such as payer interfaces or vendor tools, influence your plan for implementation. Keeping in mind that IT systems are dynamic, it is important to learn the system gaps and redundancies, and work toward process improvements.

  • Vendor Readiness – It is extremely important to know whether your vendors will be ready for ICD-10 and how much it will cost for your vendors to make your systems ICD-10 ready. Working one-on-one with the budget team will be imperative for financial planning, as will taking the opportunity to look for new vendors, if warranted.

In the referenced Wolters Kluwer whitepaper, you will find that the points noted above are discussed thoroughly and provide ample ICD-10 readiness assistance. In times of uncertainty it is important to understand what is at stake – in this case, with or without an implementation delay. There are many opinions and insights floating around as they relates to the potential ICD-10 delay, and in my opinion now is not the time to take a break and put your feet up. Now is the time to understand how you are doing business, regardless of the implementation date.

About the Author

Maria T. Bounos, RN, MPM, CPC-H, is the Business Development Manager for Regulatory and Reimbursement software solutions for Wolters Kluwer.  Maria began her career at Wolters Kluwer as a product manager, responsible for product development, maintenance, enhancements and business development and now solely focuses on business development.  She has more than twenty years of experience in healthcare including nursing, coding, healthcare consulting, and software solutions.

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