Our summer is now complete, as we actually know the implementation date for ICD-10, thanks to the Aug. 24 announcement and publishing of the U.S. Department of Health and Human Services (HHS) final rule establishing Oct. 1, 2014 as the compliance deadline for converting to the ICD-10-CM and ICD-10-PCS coding systems.
Now is the time to dust off your ICD-10 implementation road map if it was shoved on the back burner by other initiatives. With the definitive date in place, it makes sense to refocus your planning, mitigation and training efforts to simplify the transition.
Do not further delay the alignment of your American Health Information Management Association (AHIMA)-certified ICD-10 trainers with a solid and functional clinical documentation improvement (CDI) program, supported by physicians and the senior executive management team.
The key to successful ICD-10 transition is to mobilize an expert CDI, coding and auditing team to take on your toughest documentation challenges identified through ICD-10 gap analysis. Another wise move would be to shore up your CDI program if it has run out of steam. Many organizations have acknowledged that the delay knocked their ICD-10 roadmaps off course, and many are having a hard time regaining the momentum that was lost and the resources that dried up. Significant barriers associated with the launch or re-launch of your training program also need to be addressed.
From a project plan perspective, one of the key decisions to be made involves electing whether to adjust the dates if you stayed on course, or to spend the additional seven to nine months prior to Oct. 1, 2014 performing end-to-end testing with your payers and vendors. If you have not started your gap analysis and readiness assessment, you are not alone, but you need to compress your time frame and ensure that you have a consultative partner that can accelerate this process, leaving adequate time for testing.
The other key decision to be reexamined is electing when to launch a parallel coding effort. There are many approaches organizations have taken to address the ICD-10 parallel data coding effort. A number of organizations have a focused approach through which they dual-code the areas that are most problem-prone (based on issues identified from the coding impact analysis) and then utilize this information to feed the CDI effort and sharpen the content needed in the EHR documentation template. This approach is the least impactful from a resource and training perspective, and it should garner the clinical documentation improvement results in front of the implementation date.
Some organizations have decided to implement their ICD-10 coding programs a full year before the new implementation date in order to test their computer-assisted coding (CAC) technology and to offer their coders plenty of training time. They are using system solutions to auto-convert ICD-10 codes to ICD-9 codes to meet the present requirements. There are obvious budgetary, technology and training demands, and furthermore, additional auditing will be necessary to ensure that conversion issues do not result in claims edit issues that will hold up the billing cycle. Another concern that has been expressed is that ICD-10-trained and certified coders will follow the money trail to meet increased demand in all healthcare sectors (and thereby leave your organization).
For those organizations confronted with a lack of physician engagement, we have a special version of ICD-10 to deal with the most difficult and resistant of physicians: ICD-10 Lite™. It is smooth, laced with a large amount of what we call the “what’s in it for me” factor and guaranteed to provide the necessary content without weighing physicians down with unnecessary details. Our own Dr. Nicholas Holmes presented aspects of this with me during the ICD-10 Summit last April, and on an edition of Talk-Ten-Tuesday. Our approach involves delivering specialty-specific sound bytes with five, not 10, tips for physicians:
- Do you treat, diagnose and document?
- Is the condition acute or chronic?
- Is the condition congenital or acquired?
- Link the organism to the infection!
- Developmental delay does not equal a diagnosis! Be specific!
The good news is that there are colleagues, outstanding companies, and professional and trade organizations that are ready and willing to serve you. The time is now if you haven’t started to launch your assessment, gap analysis, training sessions, parallel data collection, or CDI endeavor.
The health information management (HIM) community is available to lead and support you in your successful transition to ICD-10-CM and ICD-10-PCS!
About the Author
Cassi Birnbaum, MS, RHIA, 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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