Like many in the healthcare industry, Angie Comfort was left bewildered following the U.S. Senate's approval of HR 4302 on March 31, delaying the implementation of ICD-10 one year to at least Oct. 1, 2015. The extension was one line in a much larger bill delaying physician reimbursement under Medicare's Sustainable Growth Rate (SGR) formula by one year.
As director of health information management practice excellence for the American Health Information Management Association (AHIMA), Comfort had spent considerable time preparing various medical practices for the move away from the ICD-9 coding system to its successor.
"As anyone else who was prepared and really excited about the implementation being this October, I was shocked and saddened it got snuck into the [SGR] bill at the last minute," Comfort told Physicians Practice. "I'm very disappointed. We were six months away."
But now, Comfort and medical practices are at least 18 months away from using ICD-10 codes as CMS debates how it will move forward. On April 1, President Barack Obama signed HR 4302 into law, so the ball is now in CMS' court on how - and exactly when - to enact ICD-10.
But just because the immediate future is uncertain, Comfort is secure in her belief that medical practices should not abandon all preparation for the new code set.
"We will go to ICD-10," she said. "We just don't know what that actual date is until CMS gives us the date. With holding off preparations, [medical practices] are only hurting themselves."
So what should medical practices - whether disappointed that their preparations for this year are for naught or elated with the extra time - do in the immediate aftermath of HR 4302?
Comfort says there are three important steps:
1. Train• If your practice was ready: If you've already put the time and energy into learning the new ICD-10 code set, Comfort says coders, physicians, and other practice staff who have the knowledge should put it to work. "Continue to dual code [using ICD-9 codes and their ICD-10 equivalents]," she said. "If you don't use it, you lose it. We don't want the people already trained and ready for ICD-10 to lose anything they've done."
• If your practice wasn't ready: If your practice hasn't started training coders or anyone at all, Comfort advises to hold off for now. "If they do it now, and we don't go live until [2015], it will be in the back of their mind, not in the forefront as they won't be doing it every day," she said. For these medical practices, Comfort said target the latter quarter of this year or first quarter of 2015 to start ICD-10 training for a fresh start.
2. Test• If your practice was ready: CMS conducted end-to-end ICD-10 testing in early March and had planned to do more this summer. But now with the coding system delay, that future is uncertain. Nonetheless, said Comfort, if you were ready to test, then go ahead and identify key partners (clearinghouses, payers, etc.) who may also be in a position to test ICD-10 codes.
• If your practice wasn't ready: If you weren't in a position to test the new codes because you didn't reach out to your partners yet, do so now, said Comfort. "[These practices] need to talk to their vendors about readiness," she said. "Is their EHR going to be ready for ICD-10? What about their payers? Start discussing these things now" with future testing partners.
3. Talk
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• If your practice was ready: While you may be dismayed by Congress' actions this week, Comfort said don't let a speed bump derail your whole path to ICD-10. "Just stay the course. Continue to do what you are doing for your ICD-10 implementation as if it was happening in six months. You still need to know it; you still need to be training. If you've already learned it, you need to continue to use it, if not on a daily basis, then weekly. Keep it fresh in your mind."
• If your practice wasn't ready: First, notes Comfort, don't get lulled into a false sense of security that Washington, D.C., just preserved ICD-9 for the long term. It's time to focus on ICD-10 at your practice right now. "ICD-10 will eventually happen; it has to," she said. "ICD-9 is totally outdated. There is not enough specificity … and we have to catch up with the rest of the world. Without a plan to train and prepare for the coding transition, when the coding system switch is made, "these [practices] could possibly go under because they are not billing correctly and getting paid correctly." The one upside to the delay, Comfort added, is that practices - even those that have prepared - have additional time to reconsider budgeting for IT upgrades they could not afford in 2014. "Maybe they can find something to help them get ready for ICD-10 in 2015."