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The comments have been reviewed, the speculation is over, and now we know that the ICD-10 implementation date is Oct. 1, 2014. So, what’s next? How do you proceed from here? What are the different considerations that need to be given regarding a one-year delay?

At Blue Cross Blue Shield of Michigan, we were fortunate enough to continue our transition work during the entire ruling and comment period. Because of that, much of our internal work either is nearing completion or scheduled to be completed on time. Basically, anything that can be done ahead of time will be done ahead of time.

One thing the ICD-10 discussion and delay afforded us was the opportunity to look ahead and spend time thinking through how we will work and test with our external stakeholders. What we discovered is that, even with the one-year delay, time is still running short.

Payers working with providers

A huge challenge for payers as it pertains to ICD-10 implementation will be to assess the true status of healthcare providers’ readiness for the transition. Why is this important? It has to do with the associated ICD-10 codes payers will receive from providers.

The codes that come into play with payer systems have the potential to impact several areas, including payments, servicing, benefit application, reporting, predictive modeling, underwriting, etc. Getting a good sense of what healthcare providers will send enables payers to plan for the new reality of ICD-10 codes. This is going to require extensive collaboration, which will demand time and resources.

In addition, it will take time and resources to define and build the test environment required to support testing with these external constituents.

Don’t forget about other external impacts

A one-year delay puts ICD-10 implementation squarely in the middle of the health information exchange (HIE) timeline. This isn’t a bad thing, but it’s something the industry didn’t have to look at as closely while planning for the original Oct. 1, 2013 deadline.

It’s critical that entities understand and weigh the impacts of health information exchange on ICD-10 planning. This includes understanding HIE-based products, the impact on existing products, and what it would mean for your company’s planned neutrality/new reality position.

All in all, the extra time helps, but it also adds complexity.

About the Author

Dennis Winkler is the Technical Program Director of Program Management and ICD-10 for Blue Cross Blue Shield of Michigan and Blue Care Network of Michigan. He is responsible for ICD-10 program direction and is the IT business partner for Medicare Advantage. Winkler joined BCBSM in 1998 and since has been responsible for leading major enterprise programs including HIPAA 4010 implementation, Social Security Number elimination and the National Provider Identifier initiative, among others. He has spoken at several national summits and seminars about ICD-10 since BCBSM began its ICD-10implementation.

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