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“We’re panicky.”

That statement was the start of an email query I received from an anxiety-ridden office manager at a solo practitioner neurology office in the deep South.

This high importance-flagged query was concerned with how the provider, running a small, barely-staying-afloat office, would be able to foot the bill for a billing system upgrade or the purchase of an entirely new billing system to accommodate ICD-10-CM. Their current system, purchased many years ago, is an older version of a nationally known but still off-the-shelf medical office billing system that is fixed, not allowing any changes to its format or architecture.

“The extra dollars to remedy this problem alone, not even considering ICD-10-CM code training, books, tools, etc., is likely to drive us to the brink! We don’t know where to turn for information. Help!” he concluded.

There are options, and timing is everything. While the following answer is not meant for every “small physician practice” (by the way, that OIG-coined term doesn’t mean Napoleon-sized physicians, just closet-sized practices), there is a possible resolution nonetheless. It’s called the “EHR Incentive Program,” otherwise widely known as the “meaningful use” subsidy. That’s right, in this election year of bitter arguments over the government’s role in our lives, one can look at this program apolitically and in that approach—for pure economics—turn to the outstretched Federal hand for a boost. It’s not just for small physician practices, either. Philosophical arguments aside, if there’s assistance out there, shouldn’t physicians at least take a closer look at this possible advantage for upgrading to the electronic exchange of health data and incorporating the ICD-10-CM code data sets in one fell swoop?

EHR Incentive Program

The EHR Incentive Program is part of the HITECH Act of 2009. This legislation has a tiered aim to cultivate the growth of EHR technology in medical offices, healthcare facilities, and other qualified providers. Again referred to as the “meaningful use” program, this implies that providers will leverage the new EHR technology in meaningful ways while supporting and delivering health care, such as by e-prescribing, efficient and expeditious health data sharing, and expanding intra-record functionality such as maintaining active medication summaries.

Providers are expected to select from a list of certified EHR technology programs and vendors, and demonstrate meaningful use of the systems (in exchange for the subsidy) over a specified timetable. At this time there are approximately 1,200 Fed-certified EHR products. But let’s not digress: the point here is that this Act grants eligible providers up to $44,000 when this program incentive is approached from the Medicare perspective; or, eligible providers working through the Medicaid program can get up to $63,750 in subsidies over specified periods (state-dependent, of course). Both of these incentive jackpots are paid out over a number of years, in a stepped plan with various criteria required for each step. More information about specifics should be sought at the CMS EHR Incentive Programs web site: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html?redirect=/EHRIncentivePrograms/30_Meaningful_Use.asp

Don’t stay behind the curve. With the revised ICD-10-CM implementation date proposed for October 1, 2014, practices now have a bit more time to get their houses in order. A recent CDC survey found that approximately 57 percent of practice-based physicians have made steps towards implementing an EHR system and currently use these systems to conduct their daily business. This is seen in the OIG report OEI-04-10-00184 “Use of Electronic Health Record Systems in 2011 Among Medicare Physicians Providing Evaluation and Management Services,” June 21, 2012. This study was performed, in part, to ascertain EHR documentation vulnerabilities in one of the largest buckets of paid health care services under the Medicare program: Evaluation and Management, or E/M, services. Significantly, 22 percent of the total number of “Medicare physicians” began using EHR in 2011, which is, not so coincidentally, when the EHR Incentive Program was launched and began doling out e-system subsidies to eligible medical offices.


In circling back to the original query, there are other ways to float this expense and get onboard with ICD-10-CM without accessing the Fed “meaningful use” subsidy. Aside from winning your state lottery, these might include traditional routes of financing upgrades to your current system or purchasing an entirely new system that allows for future system upgrades and updates.

If that’s not palatable, perhaps a cost sharing arrangement with your current vendor can be hammered out. In order not to lose your loyal business, some vendors may share the financial burden of upgrading or enhancing your current EHR system. For example, for a nominal fee they might restructure or rebuild your original e-system’s architecture to adapt the new HIPAA ASC X12 Version 5010 e-format to accommodate the expanded ICD-10-CM diagnosis codes and ICD-10-PCS procedure codes (which was required at the close of June 30, 2012 for HIPAA covered entities), build in the ICD-10-CM library, and manipulate the system so that for a time, you can actually run parallel billing efforts by reporting ICD-9-CM codes as well as ICD-10-CM codes during your initial trial run. If outsourcing is on your list of considerations, various billing companies and claims clearinghouses are upgraded to the 5010-format and are making their own preparations for the ICD-10-CM/PCS implementation.

Help is available! Aside from various consulting firms that assist in the ICD-9-CM-to-ICD-10-CM conversion process, there is a recognized and leading resource in ICD-10-CM/PCS information easily accessed for at-a-glance data on vendors to help you. The Workgroup for Electronic Data Interchange (WEDI), at the following link, lists numerous resources in its ICD-10 Vendor Resource Directory:


Start a spreadsheet. Compare services and prices, as well as timelines. Many vendors and consulting firms have “topped out,” meaning they’ve taken on as many clients as they can reasonably handle in the conversion, implementation, and training for ICD-10-CM/PCS. But just as many are waiting to help.

Choose one that’s right for your practice, the services you provide, your current patient volume and expected growth (patients, new providers, additional services, etc.). Consider all alternatives and viable approaches. A new billing system, a rebuilt or revised system with new infrastructure and modules, the Federal EHR Incentive Program, outsourcing, whichever… there are answers!

About the Author

Michael G. Calahan, PA, MBA, is the director of physician services at Healthcare Consulting Solutions (HCS) and is an AHIMA-Certified ICD-10-CM/PCS Trainer. Michael has more than 25 years of experience in health care, beginning as a physician assistant with the USN. He has served as an administrator for several physician practices and has enjoyed a varied career in healthcare consulting, being affiliated with Ingenix, CGI, Navigant, PWC and Parente-Randolph. He has authored numerous industry publications and articles in physician, IP/OP/ASC, DMEPOS, ESRD, HHA, ambulance, HIPAA and in Medicare Parts C & D for Medicare Advantage.

Contact the Author

mcalahan@hcsglobal.net or mikiecal@hotmail.com

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Michael Calahan, PA, MBA, AHIMA-Approved ICD-10 CM/PCS Trainer

As Vice President of Hospital and Physician Compliance at HealthCare Consulting Solutions (HCS), Michael G. Calahan, PA, MBA, provides subject matter expertise and consulting services. He has been a speaker for MedLearn for nearly 10 years and has provided webinars on device credit reporting since 2013.

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