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According to the Centers for Medicare & Medicaid Services (CMS),  the ICD-10-CM and ICD-10-PCS code sets will be implemented on Oct. 1, 2014 – and on that date medical practices and their billing service companies, clearinghouses, and all covered entities and payers will need to use ICD-10 codes. There are two crucial ICD-10 transition milestones for providers to meet in 2013.

The first milestone fell on April 1, the date by which internal testing of ICD-10 code sets with colleagues, coding, billing, and clinical staff within each practice should have commenced. Use ICD-10 codes for the diagnoses seen most often in your facility and test data, claims, and reports for accuracy.

The second crucial milestone falls on Oct. 1, 2013: the date when practices should begin external ICD-10 testing with their business trading partners (payers, clearinghouses, and billing services).

WEDI Readiness Survey Results

In February 2013, the Workgroup for Electronic Data Interchange (WEDI) conducted a seventh ICD-10 readiness survey. Nine hundred and seventy-four industry participants were surveyed, including778 providers, 109 health plans, and 87 vendors. The results indicated that more than 40 percent of providers surveyed were neither aware of the expected completion date of the ICD-10 assessment, nor when they were to complete operational changes to accommodate the expanded code sets. The most commonly reported obstacles for providers were evenly split between competing federal mandates, staffing, lack of funding, and the impact on information systems.

Two-thirds of system vendors also indicated that they plan to begin beta testing by the end of 2013. Overall, the majority of respondents won’t begin testing until 2014. Health plans were evenly divided between those expecting to start external testing before 2014 and those expecting to begin after 2014.

Provider Readiness

Provider readiness is still a major concern now, when the compliance deadline is 15 months away. Providers must move forward with transition efforts to avoid disruption to workflow and operational processes. They also must prepare for adequate end-to-end testing within the time frames suggested by CMS. This will require dedicating ample time to perform this very important function. It is critical that providers get started right away; they can begin by taking advantage of the free information and tools available from CMS, the Healthcare Information and Management Systems Society (HIMSS) ICD-10 Playbook, and resources from other associations such as the American Health Information Management Association (AHIMA) and AAPC.

To utilize the tool sets provided by CMS and HIMSS effectively, healthcare providers must understand the roles each of these organizations’ tools  serve, plus how to access them. CMS will provide detailed timelines and checklists for activities that providers and payors need to engage in to prepare for ICD-10.


On Sept. 28, 2012, based on industry feedback and participation, CMS awarded National Government Services (NGS) a one-year contract to develop a process and methodology for end-to-end testing of the administrative simplification requirements. This process represents an industry-wide best practice for end-to-end testing that lays the groundwork for more efficient provider testing of future standards, which will lead to more rapid adoption. While the goal is identifying a process that can be used across all administrative simplification requirements, ICD-10 will be the test case used during the pilot.

The HIMSS/WEDI ICD-10 National Pilot Program, a collaborative initiative, is being established to assist the healthcare industry in its efforts to prepare for ICD-10 testing and to share best practices from early adopter organizations.

All reports, updates, communications, and standardized testing scenarios from the program will be co‐published by HIMSS and WEDI in the ICD‐10 PlayBook (www.himss.org/ICD10PlayBook) free of charge for all HIMSS members and non‐members. Program reports will outline identified issues, success points, best practices, early findings, and other outcomes data from participating early adopters.

Industry participation is essential to this project, and providers can participate by becoming a collaboration partner, providing feedback in industry listening sessions, or serving as a volunteer to pilot the end-to-end testing process.

Twelve Tasks to Achieve ICD-10 Compliance

Task No. 1: If you have not already begun the initial task of organizing your implementation effort, it is estimated to take two to four weeks. This task entails becoming familiar with ICD-10-specific requirements, identifying a project manager and key personnel to be involved, setting a schedule with critical dates for project meetings, and creating a preliminary budget for the work.

Task No. 2: The second task is to analyze the projected impact of ICD-10 implementation on your organization. The average estimated time to complete this task is two to three months. Key elements include creating an inventory of all current electronic and paper systems, processes and workflows that use ICD codes. This should involve the vendors that support the codes and the supplies and products used (such as encoders or code books and other materials), as these all must all be upgraded or converted to ICD-10. This task includes completing an organizational assessment to determine all aspects of the practice that may be affected by the implementation of ICD-10.



Task No. 3: The third task is to contact your system vendors. The estimated time to complete this task averages one to two months, although follow-through will continue to the go-live date. Key aspects of this task involve contacting your various system vendors to determine their timelines for updating their systems and products for ICD-10, plus establishing when they will upgrade your systems. Remain in close contact with your vendor(s) regarding the status of their work and that of your upgrades or installations.

Task No. 4: The fourth key task is to prepare a budget for implementation. The estimated time to complete this task averages two to four weeks, but it is an evolving process. Key elements are budget inputs based on your impact analysis and discussions with your system vendors. Remember, your budget likely will change due to the multiple and intersecting updates from your various departments. An example of this is the cost of education and training.

Task No. 5: The fifth task is to contact your trading partners and clearinghouses. The estimated time to complete this task can range from one to two months, and this too is an evolving process. Key elements involve contacting your billing service vendors, payers, and clearinghouses to understand their implementation plans and time frames. Also ask about their testing processes and when you will be needed to coordinate migration tasks with them.

Task No. 6: The sixth task is to implement system and software upgrades throughout your enterprise. The average time to complete this task can be anywhere from three to six months. Key elements entail implementing the end-to-end testing requirements and understanding that the timing of this work will depend on vendors’ readiness and how many of your systems will require upgrading.

Task No. 7: The seventh key task is to conduct internal testing. The average estimated time to complete this is one to two months. It will require using ICD-10 codes within your systems and operational workflows to ensure that they can accept and process the new code sets.

Task No. 8: The eighth task is to update internal processes. The estimated time to complete this task can range from one to two months. Key elements include adhering to federal and state reporting requirements, plus updating any internal workflows and manual processes for ICD-10, including policies and procedures, encounter forms, clinical documentation, electronic health record templates, and pick lists.

Task No. 9: The ninth key task will be to conduct staff training. This task will consist of addressing the various staff populations within your organization that will require some form of ICD-10 training or awareness. The estimated time to complete this task averages from one to two months preliminarily, but it will continue through the go-live date and beyond. Key elements entail identifying which key staff members, including members of the clinical staff, need to be trained on ICD-10 and how much training each individual will require. You will need to arrange for this training and purchase training materials. It also is critical to allocate enough time for this important task, as it directly impacts the providers and documentation inside and outside of your organization. Another key requirement is to implement your dual-coding effort. Dual coding will require careful planning and strategy to achieve optimal measurable outcomes.

Task No. 10: The 10th task is to conduct external testing of transactions using the ICD-10 code sets. The average estimated time to complete this task ranges from one to two months. It will require testing of various transactions, which also may involve claims submission and eligibility requests with your trading partners, clearinghouses, billing services, and payors in order to ensure that the ICD-10 codes can be transmitted and interpreted properly by the various systems involved. Expect to continue testing transactions and fine-tuning your transition protocols right up until the ICD-10 compliance date of Oct. 1, 2014.

Task No. 11: The 11th task will be the actual implementation of ICD-10. Again, everyone will be switching to using only the ICD-10 code sets for dates of service beginning on Oct. 1, 2014. Dates of service prior to Oct. 1, 2014 will require the continuing utilization of ICD-9 code sets, thus necessitating dual coding for an indeterminate amount of time. Industry estimates indicate that there will be an overall 50 percent decline in productivity during the first six months of the transition to the new code sets. Once the dust has settled and workflow processes throughout the organization begin to assimilate the new code sets, however, the permanent estimated productivity loss has been gauged at 15 percent.



Task No. 12: The 12th key task will be monitoring of the use of the ICD-10 code sets. The estimated time to complete this task is three to six months. Organizations will be monitoring the use of the new codes to ensure proper claims submission and receipt. Reimbursements should be analyzed to determine if they are being paid at the expected amounts for the services provided, based on previous reimbursement history under ICD-9.

Achieving these milestones will require the utilization, coordination, and collaboration of key personnel within your organization, plus the establishment of milestone-critical dates. To assist you with planning, the CMS timeline below is a good baseline to use.

Source: CMS (http://www.cms.gov/Medicare/Coding/ICD10/Downloads/ICD10LargePracticesTimelineChart.pdf)

About the Author

Anita Archer has extensive management experience in the healthcare industry, with an emphasis on revenue cycle management and systems implementation and support. She is a certified professional coder and an AHIMA-approved ICD-10-CM/PCS trainer, and has been responsible for revenue cycle improvements in physician practices, hospitals and ancillary services. She has extensive system implementation experience and is a superb project manager and team leader. Anita is currently the director of regulatory compliance at Hayes Management Consulting.

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