This time last year, the healthcare industry was gearing up for ICD-10 implementation in October. Fast-forward twelve months … and the healthcare industry is gearing up for ICD-10 implementation in October. As the great Yogi Berra once remarked, “It’s déjà vu all over again.”
At press time, all systems seem a go for an October implementation, with a few expected hang-ups along the way. A March 4 statement from the American Medical Association (and 99 state and specialty societies) expressed concern that “there are not sufficient contingency plans in place to avoid anticipated failures that could result in a significant, multibillion-dollar disruption for physicians and serious access to care issues for Medicare patients.”
However, Scott Mertie, CHFP, CMPE, president of Kraft Healthcare Consulting, noted that during the March 9-10 Leadership Healthcare Delegation to D.C., the possibility of another delay was dismissed by the Washington thought leaders and policymakers. Presenters expressed confidence that hospitals and CMS were prepared for the transition but did discuss the possibility of a brief phase-in period under which both ICD-9 and ICD-10 would be accepted.
Local experts like Lori Nobles, RHIA, CHTS-IM, CPHIMS, principal at Cumberland Consulting Group, said a slight chance of deadline extension still looms, reviving the prudent yet lesser known saying, “Fourth time’s a charm.” In the 2009 final rule, implementation was delayed from the proposed date of October 2011 until October 2013. In September 2012, HHS issued a one-year delay, changing the final compliance date to October 2014. In March 2014, Congress voted to delay ICD-10 again. Oct. 1, 2015 was then set as the new implementation date.
Nobles, who specializes in health information management, said some concern still evolves around the financial impact on smaller practices. “They’re already being asked to do so much to meet the government’s Meaningful Use requirements and can’t absorb any more costs,” she said. “They’re not totally opposed to ICD-10, but they want it spaced out.”
Ghosts of Deadlines Past
While national efforts like “Coalition for ICD-10” have supported a 2015 implementation, some critics have been circling the “Let’s skip ICD-10 and go straight to 11” camp. While version 11 is currently in beta draft and scheduled to go to the World Health Assembly for approval in 2017, there’s no migration plan from 9 to 11, making 10’s structure necessary for future versions. “Once 11 is available, the U.S. has to put in clinical modifications, which takes several years,” Nobles explained. “We’re the only country using it for financial reimbursement, so we have to modify everything.” Still, she anticipates the transition to 11 will be simpler as the most painful part is happening in the transition to 10.
For many hospitals ready to pull the trigger in 2013, the delay meant a temporary halt on a $1 to $3-million technology investment. “They’ve already upgraded systems through vendors, invested time in testing with vendors and trained staff,” Nobles said. “They were ready last year when it stopped, so for a year many haven’t pushed providers to continue training or using terminology and a lot of hospitals have moved financial resources to other projects. It’s a challenge at this point because people don’t think it’s going to happen.”
Another delay-related challenge is coder training and turnover. Many accredited programs had begun teaching coders ICD-10, and now those coders don’t know how to code in ICD-9, Nobles said.
For some hospitals, the delay provided one more year of dual-coding practice under both ICD-9 and 10, although the number of facilities actually doing this is unclear. Software vendors also had extra time to work out quirks – assuming hospitals kept testing.
What Now?
Three-plus years of “I’ll believe it when it happens” mentality begs the question, what should practices be doing now?
Assuming ICD-10 goes live Oct. 1, staff should already be trained and submitting test claims to Medicare, CMS and other payers to work out kinks. Dual coding also helps hospitals and practices see where financial hits might come from: is it because provider documentation isn’t adequate, or because more education is needed? Identifying those areas now will help lessen the blow once systems go live.
Nobles said the biggest challenge organizations are facing is lost momentum and trying to get it back. Organizations that haven’t lost momentum have continued to move forward with testing, training and dual coding. “Many practices conducted training; but ‘til you start coding and sending out claims, you don’t know how successful that’s been,” Nobles said. “You can turn right around and incorporate that into clinical documentation improvement programs and tools on the front end so that by the time the patient is discharged on the back end everything is ready to go.”
Monica Smith, RHIT, CPC, coding and compliance consultant with Kraft Healthcare Consulting, LLC, said it’s especially imperative for specialty groups like orthopaedics to familiarize themselves with the diagnosis portion of ICD-10. That’s because coding will become much more specific, i.e. where an injury is located, which bones are involved and what specific treatment is needed.
For inpatient facilities, Smith said the procedure portion of coding will be completely different and will require extensive training. While she’s seen more inpatient systems prepared than outpatient, Smith said many remain fearful of the change until they undergo training.
“I encourage clients to take advantage of training opportunities like workshops and boot camps, which can be tailored to specific specialties,” said Smith, a certified AHIMA-approved ICD-10 trainer who provides training nationwide. Like Nobles, Smith also associates best practices with those practicing dual coding. She also assures clients that, despite its learning curve, ICD-10 isn’t the monster many make it out to be. Others have compared the switch to putting off a root canal. While the process is painful, it’s unavoidable in the end.
“Don’t be afraid of ICD-10,” Smith advised. “It’s definitely needed, as we’re the last industrialized country to update our system to allow for new conditions and diseases.”
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