Implementation: ICD-10 Lessons Learned

EDITOR’S NOTE: George Vancore appeared during a recent edition of Talk Ten Tuesdays focused his report on lessons learned during the implementation of ICD-10 in preparation for ICD-11. This article is a summary of his remarks.

When Chuck Buck recently asked whether I could summarize Florida Blue’s ICD-10 implementation success in four minutes or less, I told him, probably not! What I can do, though, is provide you with three simple things that we took away from our ICD-10 implementation that you may find valuable.

As some of you may recall, Florida Blue’s ICD-10 implementation was the biggest non-event since Y2K, and it all came down to three simple things:

  1. Communication
  2. Contingency Planning
  3. Testing

These all seem simple enough, but not so fast. Let’s take a quick look at each in more detail.

Communication:
Most of us take a traditional approach to communication by focusing on internal constituents. That’s OK, but recognize that there is a big integrated healthcare system world out there that we depend on to be successful. For example:

  1. Do your communication efforts include external entities like business associates, physicians, providers, delegated entities, and vendors?
  2. Do you define communication as sending a letter or posting something on your corporate Internet?
  3. Is your communication plan sustainable over time, or is it a one-and-done approach?

Well, those tactics just don’t cut it, for several reasons:

  • Have you thought about face-to-face conversations?
  • Delivering talks at medical associations and societies?
  • Hosting workshops?
  • What about collaborating with your competitors and doing a monthly call-in teleconference with a roundtable of providers, health plans, vendors, medical professionals, and consultants to share experiences?

Simply put, these sustainable tactics all worked for Florida Blue.  

Let’s turn our attention to the second factor:

Contingency Planning:
This is one area that we tend to ignore until post-implementation when it is too late. So, what did you do during your ICD-10 preparations? Did you even think about “what ifs?”

Given everything that was happening across the healthcare industry on ICD-10 readiness, did you ignore the fact that a subset of your physicians, providers, delegated entities, business associates, or vendors would not be ready? Did you implement ICD-10 with a contingency plan that said, “if you are not ICD-10-compliant, we will reject your claims?” How did that work out for you and your providers? 

What if you built in a contingency plan that enabled you to execute either ICD-9 or ICD-10 at the same time? This became known as “dual-mode processing,” but wait: if we design our systems to operate in dual mode, then aren’t we executing in a “non-compliant” mode? The Centers for Medicare & Medicaid Services (CMS) would not be happy.

  • Do you really believe that your regulator would shut you down if you discussed it with them ahead of time?
  • Do you really believe that if you documented a corrective action plan with appropriate controls and outreach strategies to work with those physicians and providers to help them get ICD-10-compliant, this would be negated by the regulator?

Let me put it this way: that is exactly what Florida Blue did! We built-in dual-mode processing created a correction action plan and reviewed it with CMS. So, when the implementation date hit, we were operating in dual mode, and it prevented over 12 percent of our electronic transactions from being rejected due to being non-compliant.  

Now, the rest of the story: 45 days later, and after a lot of work with our non-compliant senders, mostly physician practices, we were 100 percent ICD-10-compliant! This is what we meant when we said that our ICD-10 Implementation was a non-event!

Now let’s talk about the last item:

Testing:
We all do testing. We have all tested successfully with external entities that are technically capable, but what about testing with entities that are not as technically astute?

  • Do you use a testing environment that has special “test data” that resides in some internal repository somewhere?
  • Can you enable physicians, providers, vendor-delegated entities, and business associates to access this environment and its data, for testing purposes?
  • What about test data coordination between these entities? Is that even possible?

What about using your existing production environment and real production data for testing purposes? What if I built out a testing environment that contains a copy of production data, and all applicable processing rules? Can you really do that?

Take a step back for a second: if I am dual-mode capable, I can have previously processed ICD-9 claims played back into my environment after they have been ICD-10-coded by the sending entity, and route them to my testing environment!

That is exactly what Florida Blue did, and any sending entity can simply playback an ICD-10-enabled claim that will be routed to my testing platform – we would process and adjudicate the claim, create an 835, and send the information back to the sending entity for their testing.

So, in summary, Florida Blue’s ICD-10 implementation was, again, the biggest non-event since Y2K, and it all came down to three simple things: communication, contingency planning, and testing.

Facebook
Twitter
LinkedIn

Related Stories

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

I050825

Mastering ICD-10-CM Coding for Diabetes and it’s Complications: Avoiding Denials & Ensuring Compliance

Struggling with ICD-10-CM coding for diabetes and complications? This expert-led webcast clarifies complex combination codes, documentation gaps, and sequencing rules to reduce denials and ensure compliance. Dr. Angela Comfort will provide actionable strategies to accurately link diabetes to complications, improve provider documentation, and optimize reimbursement—helping coders, CDI specialists, and HIM leaders minimize audit risks and strengthen revenue integrity. Don’t miss this chance to master diabetes coding with real-world case studies, key takeaways, and live Q&A!

May 8, 2025

Trending News

Featured Webcasts

Navigating the 3-Day & 1-Day Payment Window: Compliance, Billing, and Revenue Protection

Navigating the 3-Day & 1-Day Payment Window: Compliance, Billing, and Revenue Protection

Struggling with CMS’s 3-Day Payment Window? Join compliance expert Michael G. Calahan, PA, MBA, CCO, to master billing restrictions for pre-admission and inter-facility services. Learn how to avoid audit risks, optimize revenue cycle workflows, and ensure compliance across departments. Critical for C-suite leaders, providers, coders, revenue cycle teams, and compliance teams—this webcast delivers actionable strategies to protect reimbursements and meet federal regulations.

May 15, 2025
Audit-Proof Your Wound Care Procedures: Expert Insights on Compliance and Risk Mitigation

Audit-Proof Your Wound Care Procedures: Expert Insights on Compliance and Risk Mitigation

Providers face increasing Medicare audits when using skin substitute grafts, leaving many unprepared for claim denials and financial liabilities. Join veteran healthcare attorney Andrew B. Wachler, Esq., in this essential webcast and master the Medicare audit process, learn best practices for compliant billing and documentation, and mitigate fraud and abuse risks. With actionable insights and a live Q&A session, you’ll gain the tools to defend your practice and ensure compliance in this rapidly evolving landscape.

April 17, 2025
Utilization Review Essentials: What Every Professional Needs to Know About Medicare

Utilization Review Essentials: What Every Professional Needs to Know About Medicare

Dr. Ronald Hirsch dives into the basics of Medicare for clinicians to be successful as utilization review professionals. He’ll break down what Medicare does and doesn’t pay for, what services it provides and how hospitals get paid for providing those services – including both inpatient and outpatient. Learn how claims are prepared and how much patients must pay for their care. By attending our webcast, you will gain a new understanding of these issues and be better equipped to talk to patients, to their medical staff, and to their administrative team.

March 20, 2025

Rethinking Observation Metrics: Standardizing Data for Better Outcomes

Hospitals face growing challenges in measuring observation metrics due to inconsistencies in classification, payer policies, and benchmarking practices. Join Tiffany Ferguson, LMSW, CMAC, ACM, and Anuja Mohla, DO, FACP, MBA, ACPA-C, CHCQM-PHYADV as they provide critical insights into refining observation metrics. This webcast will address key issues affecting observation data integrity and offer strategies for improving consistency in reporting. You will learn how to define meaningful metrics, clarify commonly misinterpreted terms, and apply best practices for benchmarking, and gain actionable strategies to enhance observation data reliability, mitigate financial risk, and drive better decision-making.

February 25, 2025

Trending News

Celebrate Lab Week with MedLearn! Sign up to win one year of our Laboratory All Access Pass! Click here to learn more →

Prepare for the 2025 CMS IPPS Final Rule with ICD10monitor’s IPPSPalooza! Click HERE to learn more

Get 15% OFF on all educational webcasts at ICD10monitor with code JULYFOURTH24 until July 4, 2024—start learning today!

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24