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As we continue to wait for the ICD-10 implementation final rule to be issued by the U.S. Department of Health and Human Services (HHS), it is important for health information management (HIM) directors to stay the course and continue their ICD-10 preparations. This delay provides an opportunity to refocus efforts and get it right.

The transition to ICD-10 will be monumental, and there are a few things to determine now, while you still have the time. This isn’t just a change for coders – it is a paradigm shift. HIM directors must be highly visible and assure their departments and facilities that they will be ready.

What areas should HIM directors be thinking about now? Preparation and planning are key, and facilities should be giving thought to coding, clinical documentation improvement, denial management and system implementation and testing.


Coding productivity is projected to decline 40 percent during the first year following ICD-10 implementation, with that figure shifting to 20 percent after the first year. It’s important to align priorities now to ensure that you are ready. HIM directors must assess current coding volume as well as projected volume, and they must determine their coding staffing needs. Questions to consider include the following:

  • Do you have skilled coders today who will remain with your department throughout the transition?
  • Are those skilled coders highly productive? Are their quality ratings above 95 percent and monitored consistently?
  • How many coders will need to be cross-trained in order to manage this change effectively?
  • Will any new ICD-10 service lines be implemented?
  • Do staff members have the coding skill sets to accommodate the addition of these new services?
  • Will there be any type of merger with another facility in the near future? If so, will those aforementioned employees remain at the same level?

In assessing needs for additional staff, remember that you will be training up to the moment of implementation (and then re-training some of them). And beyond these, there are other questions to consider.

Clinical Documentation Improvement

Does your facility currently have a clinical documentation improvement (CDI) program that can support the need for appropriate documentation? Have you considered the role technology plays in facilitating your CDI program? Plans should include having additional staff on hand to support working closely with physicians and providers to obtain the level of documentation required for this change. Look at your mix now and determine areas that may change, and where the need to focus is as it pertains to CDI.

Denial Management

If your department is involved in denial management, have you prepared the staff to support this change? Based on recent denial statistics, will it be necessary to expand the staff in this area? Trending will be imperative, as will action plans and communication within the revenue cycle, to determine root causes of denials and to ensure that your facility proactively addresses documentation issues.

Denials certainly are going to increase with the transition to ICD-10. Having the ability to staff accordingly, to review letters and documentation for appeals, and to provide educational information to providers, HIM coders, CDI specialists and others will allow for a faster approach to getting processes on track.

System Implementation and Testing

Are you working with the information technology (IT) and revenue cycle teams to create a timeline of updates, changes and testing that will be required? Have you accounted for this need in terms of additional labor resources?

Is your coding manager involved now with that type of testing? As the implementation date draws closer, this person will need to wear many hats. Remember, there is still current work to contend with, as well as education of coders. Make sure your coding manager is up to the task.

It will be imperative to work as a team within several areas of your facility. HIM staff typically are accustomed to being leaders and participating with task forces over the years. Recently you’ve also probably been involved with EHR implementation, meaningful use projects, etc. The transition to ICD-10 is an opportunity to display your leadership skills by asking your executive leaders, “Do we have a written plan?” Look at where your needs are and prepare the business case regarding staffing needs for your department. Begin now, if you haven’t done so already, in order to see where your gaps are –and work with the team, emphasizing education and human resources, to prepare for your facility’s future.

About the Author

Kay Ennis, RHIA, is a director of HIM strategic sourcing accounts for Precyse. With more than 30 years of industry experience, Kay provides oversight for clients who have contracted with Precyse to provide operational management of the HIM departments within their facilities.

To comment on this article please go to editor@icd10monitor.com


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