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As we continue to move toward the new ICD-10 coding and reimbursement system, new challenges are facing healthcare providers above and beyond those associated with other high-profile federal mandates.

New focuses demanding our attention and resources include the fearsome Ebola virus and Enterovirus D68 (EV-D68), which is more easily communicable than Ebola and appears to have spread to children in 45 states and the District of Columbia (as well as other humanitarian crises overseas that now are impacting the U.S.) Although we often prefer to distance ourselves from diseases that we’ve not treated in the past, the reality is that many of these diseases could eventually find their way to the U.S. if we’re not able to contain them abroad.

These new urgent priorities have caught us halfway into preparing for ICD-10, the basic foundation we need to support current practices of medicine and to track health of various populations in the 21st century. To obtain the latest information on industry progress on implementation, we asked ICD-10 expert consultants to share their assessments and recommendations about ICD-10 testing. These consultants serve in leadership capacities on behalf of their hospital and ambulatory clients across the U.S. 

Specifically, they’ve been engaged to function as ICD-10 program directors, project managers, testing SMEs, testers, analysts, strategists, and overall implementation advisors.

We asked the consultants, “Where is the industry at in terms of testing for ICD-10?” The responses are organized in three categories: “the Good” (what is going well), “the Bad” (areas in need of improvement), and “the Ugly” (critical areas of focus that impact overall success of any organization).

The Good:

ICD-10 consultants report that most health systems have been actively remediating their applications and IT systems. They have a thorough test strategy and test plan that includes utilizing dual-coded medical records and claims as a basis for their test scenarios and test scripts. Many are now working toward clinical, computer-assisted coding (CAC), and dual-coding go-live events while preparing to test with the Centers for Medicare & Medicaid Services (CMS). Some have successfully completed integration testing with electronic health records (EHRs) or are currently in the process. They are right where they need to be in terms of timelines.

For small and large hospitals alike, unit and integration testing appears to be the easiest to perform, since these are often simple upgrades. Vendors often inform IT teams where changes were made and where codes are located. They also often provide test scripts, which allow for testing to be completed almost as quickly as the upgrade arrives. 

Because they have developed test scripts to get as close to real workflows as possible, hospitals are later able to save time in confirming actual operations and processes with their end-users (“super users”) as they prepare for user acceptance testing (UAT).  

Hospitals have also identified technologically savvy physicians to guide their peers, which seems to result in greater buy-in. These physician champions explain their role in ICD-10, what the expected ROI is for them (as well as for the healthcare community in general), ICD-10’s role in global health, and how to move towards clinical documentation improvement (CDI). 

The Bad:

Consultants often are faced with a deficit of testing resources for key projects and overwhelmed leadership that can’t properly support those projects. Other major concerns include having numerous hospital IT systems and applications running with unknown or undocumented workflows, causing project delays and people/resource downtime.

Additionally, according to ICD-10 testing consultants, some big challenges for small and large hospitals include: 

  • Major changes involving new platforms or clinical systems
  • Interfacing CDI/CACs with legacy systems
  • Highly customized EHRs, which are taking longer for vendors to remediate and upgrade
  • Not having an ICD-10 test strategy and test plan in place that have been well-communicated to the proper internal stakeholders before attempting testing
  • Lack of test environment planning   
  • Not enough committed hospital SMEs allocated to the testing project
  • No allocated/dedicated people, resources, space, time, etc.
  • Limited or no access to IT systems
  • Inappropriate test environments chosen 

The Ugly: 

Although there are few areas that fall into this category, ICD-10 testing consultants did emphasize the following factors that can negatively impact enterprise operations: 

  • Organizations being caught up in major systems upgrades with no awareness of testing requirements
  • Lack of communication between consultants, PMOs, and organization decision-makers
  • Lack of advanced testing preparations prior to launching testing efforts
  • Lack of importance placed on regression testing (a critical step that is often skipped)


For those still undecided, the “next big thing” is here – and it’s not ICD-10. ICD-10 is just the basic foundation we need to carry on our work in caring for patients and determining the level of patient acuity on a grand scale. We must work to finalize and complete our implementation of ICD-10 in order to better track and monitor epidemics and pandemics with a high degree of specificity, accuracy, and level of severity. 

Remember that even amid all your preparing for the next big thing, it’s of paramount importance to ensure patient safety proactively by testing your systems and EMR before going live with ICD-10. 

About the Author

Juliet Santos is the ICD-10 principal consultant for Leidos Health. Santos formerly was EVP of Lott QA Group and assisted with the creation of the ICD-10 PlayBook, ICD-10 National Pilot Program, and the ICD-10 National Testing Platform.

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