On April 17, the proposed rule delaying the ICD-10 compliance date from Oct. 1, 2013, to Oct. 1, 2014 was published by the U.S. Department of Health and Human Services (HHS). According to HHS, the change is just one part of a broader proposed rule that would adopt a standard for a unique health plan identifier (HPID), adopt a data element that would serve as an “other entity” identifier (OEID) and add a National Provider Identifier (NPI) requirement.
While some are disappointed by the proposed delay, if it becomes final many vendors, providers and payers will be able to seize the opportunity to use the extra time to test their systems fully and ensure a smooth transition. As the industry moves forward with new standards for electronic healthcare transactions, the adjusted timeline offers several advantages, enabling organizations to assess processes, technology and resource requirements – and to test systems and ensure readiness by the new ICD-10 go-live date.
Leveraging the ICD-10 Delay for Competitive Advantage
Moving the compliance date will enable healthcare professionals to ensure that they can get necessary work done to prepare for all relevant legislated initiatives, including meaningful use, ICD-10 implementation and any emergent insurance or information exchange initiatives. How can your organization take advantage of the additional time and prepare for a successful transition?
Moving the timeline means there is now more time to complete an assessment.
If you haven’t already done so (and many have not), now is the time to complete your assessment. Industry best-practice timelines indicate that organizations should have completed this undertaking by now, but if not, they should not delay any longer. It is time to finalize assessment decisions, recognize the magnitude of the effort required and put plans in place to budget for and achieve successful adoption of the new code sets.
Establishing a baseline assessment with a strategic view is a critical component in implementing a successful ICD-10 adoption plan. ICD-10 is more than just a coding mandate; it impacts people, processes and technology, which is why forward-thinking organizations are aligning ICD-10 efforts with quality-of-care and process improvement initiatives.
Because of the wide-ranging impact of ICD-10, engage leadership in the decision-making process. It is critical to understand the functional changes required for training and systems, the costs of education and system upgrades, and all associated fees related to the initiative so plans can be budgeted for and supported properly throughout the organization.
While some organizations may have sufficient resources to conduct a strategic assessment, taking this on internally can shift the focus away from core business priorities. Working with an outsourcing provider frees internal resources for other work and provides external expertise for change and transition management to support adoption of new processes and systems. Another value of outsourcing an assessment is that an external reviewer may uncover details you otherwise would miss.
Use the delay to prepare and fully test systems to ensure a smooth transition.
One key lesson learned from 5010 implementation is the importance of comprehensive testing in a live production environment. Testing often is performed in a compressed time frame, but with a delay, organizations can take additional time not only to perform testing, but also to work in live clinical scenarios. Commit to comprehensive testing of top procedures and diagnoses with top payers to ensure that there is no negative impact on operations – and to validate any impact to your revenue.
Due to the scope of the coming change, testing should be performed on individual systems and as a whole. Test interoperable scenarios, from registration through to payment validation, and work extensively in the live environment in order to minimize go-live errors and process disruptions. The transition to 5010 showed that, for many organizations, while testing initially was performed on front-end systems, some claims could not flow through the entire enterprise smoothly without necessary changes being made to downstream systems.
Organizations also should take into account multiple uses and data field requirements for HPID and perform testing to ensure that claims are appropriately routed, cleanly processed and adjudicated without delay.
Take the time to finesse the documentation skills of physicians and coders.
Improved clinical documentation can impact quality of care and reporting directly. Providers can use the time freed up by the ICD-10 delay to commit to more robust clinical documentation improvement plans. Documenting to a greater degree of specificity requires that physicians and coding staff receive appropriate training and have adequate experience working with the new code set to ensure accuracy in code capture and to minimize productivity loss.
Physician training is critical because if documentation is not comprehensive and specific, coders cannot code to the greatest degree of specificity. With greater specificity in documenting care, facilities can benefit from analytic programs that scrutinize data to improve understanding of care and outcome patterns. Organizations that use the additional time to prepare providers and coders can begin connecting improved documentation to quality reporting and enhanced clinical decision support systems.
Commit to data analytics.
Consider high-value impact tools with data analytics and financial impact modeling that focus on contract terms, clinical documentation improvement, payment validation systems and other matters impacting reimbursement or quality shifts.
When payers start submitting contracts with ICD-10 reimbursement terms, providers may have limited time to analyze and recognize the impact. A modeling tool that will quickly validate the impact of any new rates and reimbursement changes will be a benefit. Look for a tool that supports even the most complex payment scenarios and modeling terms. With accurate outcomes, predictions and monitoring, you can minimize reimbursement risks upon ICD-10 implementation.
Some providers and payers have taken to negotiating an understanding about revenue impact. That is, agreement discussions are taking place regarding the idea of payers not delaying payments to providers, with each taking steps to audit and validate any noticeable changes in revenue (positive or negative) after ICD-10 goes live.
Take this extra time to be proactive about forming a strategy for recognizing and addressing any financial changes in your practice community, and for creating a model that works. Then, when you go live, make sure your system for auditing the accuracy of payments has been updated for all reimbursement methodologies. (Note: this is an example of one area where enterprise-wide testing is critical. Your models and coding tests should be validated, with your system indicating accurate processing.)
Allow for dual coding in the production environment.
Enter into a partnership with top payers to code actual claims, and take advantage of the delay by performing dual coding. This will enable organizations to recognize anticipated code change impacts with much greater certainty. Dual coding illustrates ICD-10 data trends, allows coders to practice and increase productivity, and can offer assurance that payment shifts are valid and substantiated by actual changes in patient population or documentation improvements.
As part of their processes, forward-thinking payers are engaging providers to process ICD-9 and ICD-10 codes simultaneously to validate equity in payments. Because the code sets are so dramatically different, there is no one-to-one mapping between them. Dual coding can help organizations understand the differences between the two sets and ensure appropriate outcomes.
Since organizations likely now have an additional year to prepare for ICD-10, use this time wisely to support a successful transition. Organizations that take the time to plan well, conduct complete testing, bolster clinical documentation improvement plans, perform payment impact assessments and engage in dual coding can enhance readiness and minimize disruption during the changeover and beyond.
About the Author
Veronica Hoy, MBA, is vice president of SOURCECORP HealthSERVE Consulting, Inc. Veronica has been an operating executive for 10 years, focusing on providing strategic leadership and direction to healthcare professionals and organizations. She has more than 20 years of healthcare experience in business process outsourcing, accounts receivable management, coding, billing, release of information, consulting and systems implementation. SOURCEHOV, is one of the largest pure-play business process outsourcing and consulting companies in the markets served.
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