Approaching an ICD-10 Implementation with Confidence

The deadline for implementing ICD-10 is rapidly approaching.  Providers and practices should be preparing for the transition and approaching the implementation with confidence. They should be doing this even with the recent announcement from CMS on creating a one-year grace period, allowing for flexibility in the claims auditing and quality reporting process during the transition.  Addressing the following 11 steps will help assure your practice will be on track for a successful transition on Oct. 1, 2015 and going forward: 

1. UNDERSTAND ICD-10

Review the major differences between ICD-9 and ICD-10 and how those differences will affect a clinician’s specialty as well as your organization as a whole. Reviewing the “Official Guidelines for Coding and Reporting” for ICD-10 is a good starting point. 

2.  CREATE YOUR INTERNAL IMPLEMENTATION AND COMMUNICATION TEAM

Include staff from the administrative and clinical sides of your practice and divide up the work that needs to be accomplished. Make sure you communicate the changes required by ICD-10, both from a workflow standpoint as well as clinical documentation.

3.  REVIEW THE IMPACT AREAS OF YOUR PRACTICE AND MODIFY PROCESSES

Consider all the different systems you use, the organizations you exchange data with, as well as what electronic and paper-based workflow processes you use that drive clinical encounters and the billing process.  Make sure all of these are updated and/or modified appropriately for ICD-10 compatibility.

4.  REACH OUT TO YOUR SOFTWARE VENDORS

Ask vendors about any needed upgrades to use ICD-10, what training (if any) will be needed, and cost estimates. Don’t forget to ask about the ability to concurrently use ICD-9 and ICD-10 and how long you’ll have the ability to do that.

5.  DEVELOP YOUR BUDGET

Make sure you consider software and hardware upgrades, education and training costs, the cost of temporary staff during transition should it be needed, changes to printed materials, additional time for documentation review, and the cost of lost coder, clinical and/or revenue cycle staff productivity.

6.  CONTACT YOUR CLEARINGHOUSES AND HEALTH PLANS

Ask if all their upgrades to accommodate ICD-10 have been completed and if they haven’t, when they will be. Also ask how they (the clearinghouse and health plans) will help your practice with the transition, when can you test claims and other transitions with ICD-10 codes, and whether they provide a list of any data content changes needed. Don’t forget to ask the health plans when they expect to announce their revised ICD-10-related coverage/payment changes. 

7.  IMPROVE CLINICAL DOCUMENTATION

This may be one of the most challenging aspects of ICD-10.  Identify potential documentation issues by beginning to crosswalk ICD-9 codes to ICD-10 codes. The goal should be to identify any gaps in the documentation that prevent a coder from selecting the appropriate ICD-10 code.

8.  TRAIN YOUR STAFF

Identify your education needs. While everyone will need to be trained, not everyone will need to be trained at the same level. Identify who should be trained on what.  You will also need to identify the best training mode for each group and the timeframe for providing that training. 

9.  TEST YOUR SYSTEMS

Testing is critical to success with implementation.  Plan for both internal and external testing.  This will need to be scheduled, so begin the planning now.

10.  PLAN FOR CONTINGENCIES

Every practice needs to plan for decreased staff productivity and prepare for the possibilities of other financial challenges during the initial implementation period. You should set aside some cash reserves for the practice. It may also be wise to consider establishing a line of credit. 

Preparing now for the transition to ICD-10 will help ease the burden of compliance on Oct. 1, 2015 and assure you will not have a major disruption in your practice revenue.

11. UNDERSTAND THE ICD-10 GRACE PERIOD

Make sure you familiarize yourself with the new grace period rules, including some key points below. CMS also announced the establishment of a communication center and an ICD-10 ombudsman to help receive and triage physician and provider issues. 

• Medicare contractors will not deny claims based solely on the specificity of the ICD-10 diagnosis code as long as a valid code from the right family of ICD-10 codes is used. Moreover, physicians will not be subject to audits as a result of ICD-10 coding mistakes during this one-year period.
• Physicians will not be penalized under the various CMS quality reporting programs for errors related to the additional specificity of the ICD-10 codes, again as long as a valid ICD-10 code from the right family of codes is used.
• If Medicare contractors are unable to process claims within established time limits because of ICD-10 administrative problems, such as contractor system malfunction or implementation problems, CMS may in some cases authorize advance payments to physicians. 

Mary Jean Sage is president and founder of The Sage Associates an expert consultant in billing and coding for the Cooperative of American Physicians, Inc. (CAP). CAP offers a range of products and services, including medical professional liability protection and risk management services, in the health care field. The Sage Associates is a leading multispecialty provider of health care management services.