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Let’s face it: During the ICD-10 “dark period” (the time from when the federal government in February announced that there was the potential for a delay to the recent August announcement of a final rule on the implementation date), provider organizations didn’t do a whole lot to advance their ICD-10 programs.

Sure, there was a lot of water-cooler speculation and discussion (and lots of hoping for a delay commensurate with each specific provider’s pre-dark period level of preparedness), but not a lot of real movement toward compliance.

But now it’s a new day, with a real date and a ticking clock.

We’re finding ourselves responding to a number of requests for proposals (RFPs) from provider organizations seeking to evolve their preliminary assessment deliverables into actual plans with real budgets, resource allocations and answers to a lot of questions that assessments left unanswered. Most assessments provided “ROM” (rough, order of magnitude) estimates for the costs of implementing ICD-10 and SWAGs (scientific wild-a** guesses) at the costs of resourcing for remediation and transition.

Inquiring minds want to know, however, about the engagements we’re finding ourselves in, which now seem to focus on the following assessment gaps:

Analytics – Many assessments focused on the transactional side of ICD-10 remediation and did not address how an organization would leverage analytics during the dual period (when ICD-9 and ICD-10 codes both would still be in play). Since any kind of such clinical or financial analysis requires trending (leveraging history), healthcare organizations need to decide whether they will trend by stepping past ICD-9 transactions “up” or “forward” to ICD-10, or stepping new ICD-10 transactions “down” or “backward” to ICD-9. While there are considerations either way, for a number of reasons we tend to recommend that most clients step down, or backward, when trending.


Most assessments provided lip service to testing approach and strategy. Testing for ICD-10 is a difficult, multi-variant challenge. Internal testing will be difficult enough; establishing cross-process, cross-system test cycles; generating appropriate test data; getting the right resources involved; sequencing testing to the remediation critical paths; etc., will not be easy to accomplish either. If you want to test this concept in your organization, ask three executives what an acceptable level of end-to-end testing is for ICD-10 and see if there’s any consensus. But that’s just the beginning. Establishing a proper testing program and a strategy with trading partners will be even more difficult to plan and execute.

Impact Modeling

Most programs established during assessments demanded “neutrality” (financial, operational, etc.). But most assessments didn’t establish very sophisticated models for what neutrality meant and how to measure it. There will be a lot of work to be done during the next several months to establish meaningful simulations and really model anticipated ICD-10 impacts.

Ongoing Operational Impacts – Most assessments focused on transition, or getting an organization compliant with a timing mandate, and didn’t give much attention to the ongoing operational impacts of managing a code set as comprehensive and granular as ICD-10. ICD-10 volumes will place stress on many existing processes for ICD-9 code management, and ICD-10 requires management of mappings as well.


ROMs were fine for assessments, but didn’t meet the capital allocation and budget planning needs of Johnny CFO. Real budgets are required, with pro-forma views of program spending during the next couple of years. These budgets need to be realistic and executable. A word to the wise, too: We’re finding that actual spending requirements are not always “fundable” in the current environment, which is demanding adjustments to strategy and plans.


SWAGs aren’t cutting it for managers who want to know which of their staff resources (many of whom mostly are over-allocated just doing their day jobs) need to be focused on the ICD-10 program, plus when, and for what duration and intensity. Like the budget discussion, the reality of the dearth of available resources is a key concern (which is good for consultants, but could exacerbate budget issues).

While there are other items that need to be addressed in ICD-10 restart planning efforts, these seem to be the most common and pressing issues for our clients and prospects.

Sadly, none of these are easy to address, and all require a lot of thought, discussion and debate.

About the Author

John Wollman is the Executive Vice President of Healthcare for HighPoint Solutions, a Management and Information Technology consulting firm focused on Healthcare and Life Sciences.  John is responsible for HighPoint’s Healthcare industry group, catering to Payers and Providers.  John is a recognized expert in several healthcare business domains (Reform, HIPAA 5010, ICD-10, Platform Strategy) and technical domains (Master Data Management, Analytics).  Since graduating from Duke University, John has held executive level positions at consulting and technology companies over his 25 years in business.

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