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Deb Grider

EDITOR’S NOTE: This is the second in a two-part series addressing ICD-10 implementation tasks.

As I wrote last week, some organizations, I am finding, have not even started the implementation process yet. The other day I actually became aware that one large hospital system in the Midwest just earmarked funds that originally were budgeted for ICD-10 preparations for another competing project instead, and now they do not have money to move ICD-10 forward until 2014 – and even that might be pushing it.

Even in light of the recently released final rule setting the new ICD-10 implementation date at Oct. 1, 2014, that’s a questionable move.

In the meantime, however, let’s continue with steps six through 10 on my list of the top 10 implementation tasks for ICD-10.

Step 6:

Develop the training plan, keeping in mind that it is not only coders who will need training. Many other departments and staff will require some form of training as well.

When developing the training plan, make certain you analyze who needs training, how many hours of training each staff member will need, what specific type of training each staff member needs, and whether overtime will be involved.

Training topics and time commitments will depend on the role of the staffer in the organization, but it can include documentation training for practitioners, plus an overview of ICD-10 and its projected impact, an anatomy and physiology refresher, training on system changes, new software, etc.

Some staff members may need as little as four to six hours of training, whereas coders likely will require more, depending in part on whether they are coding inpatient or outpatient claims. Physicians and non-physician practitioners will need training on documentation changes and requirements for ICD-10.

Timing is also very important. Coders should not begin training until six months to a year prior to implementation (in other words, sometime late in 2013 or early in 2014). Keep in mind that you should allow time for dual coding within your organization at least three to four months prior to ICD-10 implementation. Practitioners should begin documentation training on a rolling basis now.

Step 7:

Develop an action (project) plan and a work breakdown in order to identify timelines, duration and responsible parties.

Developing teams to implement the action plan is critical to ICD-10 success. These teams sometimes are referred to as subcommittees. If you take the action plan (representing what needs to be accomplished) and break it down by department and by teams, the task will not be so daunting.

Completing three or four tasks versus an entire list of 50 or 60 projects is less intimidating of a task. Make certain the members of the team know their responsibilities and that they complete their tasks on time. These teams are responsible for reporting results back to the executive steering committee.

Step 8:

Complete and/or update your budget. Make sure you review the budget routinely to account for unexpected costs.

Once the gap analysis and project (action) plans are developed, it will be critical to develop or update the budget, identifying both project costs and expenditures. Make sure you include in your budget system upgrades or new software purchases, ICD-10 readiness audits, education and training, as well as consulting costs.

Step 9:

Execute the action (project) plan.

The executive steering committee should be responsible for keeping all subcommittees and/or teams on task. Successful implementation depends on it.

Step 10:

Conduct ICD-10 readiness assessments.

Assess coders’ understanding and knowledge of anatomy and physiology, pharmacology, and medical terminology. Since ICD-10-CM/PCS is more robust than ICD-9, this is an important step for coders and others who will need a good understanding of the new coding sets.

Perform ICD-10 documentation reviews, identifying documentation using ICD-9 and comparing what needs to be documented in ICD-10 while providing education to fill the gaps. Starting now will ensure an easier transition for the coders, practitioners and others when ICD-10 is fully implemented.


By taking a step-by-step approach during the planning phase, successful transition to ICD-10 can be accomplished. Make certain during the year of implementation that the final phase of your ICD-10 plan includes education and training, that systems and software are up-to-date, and that processes and efficiency are improved so the entire organization will be ready to go live. The executive steering committee is a key factor in ICD-10 implementation, so make certain this committee has the tools and the time necessary to oversee a successful implementation plan.

About the Author

Ms. Grider, an AHIMA-approved ICD-10 trainer and an American Medical Association coding author, is a senior manager with herfirm, possessing more than 30 years of experience in coding, reimbursement, practice management, billing compliance, accounts receivable, revenue cycle management and compliance across many specialties. Her specific areas of expertise include medical documentation reviews, accounts receivable analysis and coding and billing education.

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