ICD-10: Are you Hiding your Head in the Sand? Assess Implement, Evaluate

One of a three-part series on the impact of technology and ICD-10

By Maria T. Bounos, RN, MPM, CPC-H Business Development Manager, Wolters Kluwer Law & Business

After studying ICD-10 for the last few years and talking with colleagues about the subject on a regular basis, I can't believe more people haven't started thinking about how ICD-10 will impact their facility from a technology perspective. It's not just about a new coding system, to say the least. When I think ICD-10 and the process involved, I specifically think about a three-year time line for implementation. But when I talk with colleagues who are performing ICD-10 impact assessments as consultants, I am learning that few have begun the process to look at the potential impact to their facilities from a technology perspective.

I'm not sure why I have a hard time believing this behavior. Some behaviors never change! It reminds me of my years in health care consulting and when there was the threat of Ambulatory Payment Classifications (APCs) implementation in 2000. Centers for Medicare and Medicaid Systems (CMS) referenced APCs for years, just as they have with ICD-10. APCs were implemented more than 10 years ago. I vividly recall discussing with clients the impact of APCs on their facility. Many looked at me and said, "it will never happen." Those same clients later called me frantically when APCs went into effect, and their facility was in no shape to perform under the new payment system. Everyone was in a panic; systems not speaking to one another, claims going out the door without codes on them, incorrect codes, duplicate codes; you name it…. all leading to increased days in accounts receivables.

Are we back there again? Do you know where your information systems are from a financial, clinical and practice management standpoint? Don't let yourself get caught up in "it's never going to happen"; the implementation date is less than three years away with a live date of October 1, 2013.

Begin Impact Assessments Now

If you have yet to start an impact assessment, it's time to start NOW! Make sure you involve the appropriate people; look at all processes, and before you train your coders, look at your technology. Every electronic transaction needs to be addressed as you begin to perform your impact assessment. Know the ins and outs of how you currently do business under the ICD-9. This will be the key to a realistic impact assessment. Let no stone, or shall I say piece of technology, paper, interface or process go unturned.

Some of the areas to look at are your software applications for medical record abstraction (e.g. your encoders), current data reporting, utilization, billing, claim submissions, groupers, and clinical systems to name a few. These areas - if not understood and managed correctly - will impact the revenue cycle when ICD-10 goes into effect in addition to decision support, storage, interfaces, edit software and contracts.

Facilitate organizational awareness through education and training. Coordinate resources and link technology with informational needs. Talk to your vendors and payers to determine their readiness; create a checklist together to assure that you have asked all the right questions. Budget for potential software and operational expenses related to ICD-10. Assess your payer contracts to assure they reflect the specifics of ICD-10; know the reimbursement impact to your facility and confirm that policy revisions are part of the overall process.

Consider the Consequences

What are some of the consequences you will face if you are not prepared for ICD- 10? Coding backlogs lead to a technology nightmare of increased claims rejections and denials, increased delays in processing, possible improper claims payment, incorrect/bad data, but most importantly compliance issues. Let's not give the third party auditing bodies any more ammunition than they already have!

Take the time to look at every department; you can't afford not to. What happens on Day 1 or should I say, what could happen on October 1, 2013? What if you forgot to look at the wound clinics and physicians in that department still document on a paper charge ticket that still has ICD-9 codes listed on it? What if the interface between health information and billing suddenly can't handle the increase in code sets with ICD-10? What if your clearinghouse has an issue? How much of a financial setback is your organization able to withstand in the budget?

As part of Implementation, we will discuss strategy and workflow. Think about Day 2 or October 2, 2013: What happens with delays? Do you have a Plan B? As a result of your impact assessment, do you plan to go early? Possibly test early in 2012? Perhaps go live in July 2012. Do you have the capability to run two coding systems (I-9 and I-10) simultaneously? When or will your vendors be ready? How and When are they going to test?

There's a lot to think about, but there's one thing I know for sure. ICD-10 is not going away, it's going to happen and go live date will be here before we know it! Learn more in parts two and three of this series, including discussion surrounding implementation and evaluation.

About the Author

Maria joined Wolters Kluwer in the fall of 2007 and is currently the Product Manager for Regulatory and Reimbursement software solutions. She is responsible for product development, maintenance and enhancements and business development. She has twenty years of experience in healthcare including nursing, coding, and healthcare consulting.

Specializing in regulatory compliance, reimbursement, and process improvement, she has led improvement projects that have delivered significant financial benefit for large academic medical centers as well as mid-sized community hospitals and critical access hospitals.

Prior to joining Wolters Kluwer, Maria was a Senior Manager with GE Healthcare and led large revenue cycle projects, developed service line offerings and mentored consultants. Prior to GE, Maria was Vice-President Operations for a national management-consulting firm, specializing in reimbursement, operational improvement, and regulatory issues. The firm provided on-site consulting services as well as web-based applications to help hospitals review and maintain their charge description master (CDM), outsource CDM management, perform outpatient and inpatient coding compliance reviews, and assist in answering corporate integrity agreements. In this role, Maria was responsible for developing and maintaining the operating budget, developing and implementing the training program for new employees, sales and implementation of web-based applications, and being the client executive for onsite engagements, as well as, providing consulting services to clients.

Maria has a Masters Degree in Public Management with Concentration in Health Systems from Carnegie Mellon University and a B.S. degree in Nursing from Carlow College. For calendar year 2006, she was the Greater Pittsburgh Chapter President of the American Academy of Professional Coders.

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