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“Mind the gap” is a common phrase I encountered on a recent trip to England, specifically referring to the London Underground, perhaps better known as “the Tube” subway system. However, this also applies to a strategy that can be deployed to facilitate training, testing, coding and documentation integrity checks and balances that need to be applied to ensure an effective ICD-10 transition strategy. This strategy will enable you to repurpose case examples that you should associate with the coding and documentation gap analysis performed following the identification of key areas to target accomplished via ICD-10 impact analysis.

If these ICD-10 compliance steps have not been undertaken as of yet, it is not too late to do some forecasting and modeling, using at least a full year of claims data to identify the shifts you will see associated with reimbursement and the associated gaps in coding and documentation. The “sanitized” medical records containing these coding and documentation gaps can be used for education, training, and testing.

However, a rich practice environment needs to exist in order to enable your coding and clinical documentation improvement (CDI) workforce to practice following training. Many organizations call this a “sandbox” or “playground” environment. You will want to simulate as much as possible regarding what goes on in the production environment, and provide access to the same technology your coding/CDI workforce will be using, if possible. The ideal environment allows for immediate feedback (both in terms of response as well as rationale) following the completion of coding. Furthermore, supervisory oversight should be provided to allow for the gauging of the progress of each coder in order to identify patterns and trends, and the training plan and content should be adjusted accordingly.

Developing a training/testing environment takes time, resources and a technology platform – so don’t try to reinvent the wheel, and leverage collaborative arrangements to ensure that this critical step is not missed in your transitional strategy. Practice is an essential element to produce a consistent approach and quality coding. Many organizations are rushing to dual coding in the production environment following e-learning, and some are scratching their heads, wondering why there is so much variation in how coding is done for the same or similar cases.

Now is the time to take a step back, take a deep breath and plan how you will create an optimal training environment and repurpose cases for testing. Many organizations are turning to their CAHIIM-approved health information technology (HIT) and health information administrator (HIA) programs to identify students who can assist with preparing a cross-section of cases to populate a training or simulated production environment. Dual coding is the most time-consuming step, but a great way to provide practice for your workforce. As far as the feedback/answer key and the administrative capabilities go, many organizations have learning management software (LMS) systems to leverage. Many smaller organizations also are collaborating on this process, and there are great opportunities to be found within the state health information management associations.

There also are vendor solutions that can be of great use, and don’t forget about the ICD-10 National Testing Program, which is a full-scale collaborative healthcare testing platform. According to the program’s website, it provides “an open and transparent process for healthcare organizations of all types and sizes to test with their trading partners for ICD-10 coding, compliance and reimbursement testing.”i There are also redacted medical records that are natively dual-coded across case types and specialties, all of which can be utilized for this same purpose. The fees for participation are low, enabling diverse provider, payor and vendor populations to participate.

Also, don’t forget to utilize your American Health Information Management Association (AHIMA)-approved ICD-10 trainers to ensure consistent, high-quality coding in the production environment following the implementation of dual coding. Use a consensus-driven approach in establishing coding guidelines, and also don’t forget to reach out to the experts. You can send your coding questions to the Coding Clinic, and the National Testing Program experts from AHIMA already are involved in ensuring that reliability is high.

For those organizations that have entered their final phases of preparation, the concern is that although the training is consistent within their workforce, variation among coding professionals remains high. This underscores the need and importance of collaboration and the establishment of consensus guidelines.

Only through practice and retraining, as gaps are identified, will your organization get to an optimized ICD-10 readiness state.

About the Author

Cassi Birnbaum, MS, RHIA, FAHIMA, CPHQ, is vice president of health information management for Peak Health Solutions, specializing in providing remote coding, auditing, data collection and analysis, clinical documentation improvement, ICD-10 transition, and HIM resource planning services nationwide. For the last 15 years, Birnbaum was the director of health information and privacy officer at Rady Children’s Hospital in San Diego, Calif.

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i (http://www.nationaltestingprogram.com/index.php, 2013)


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