D'Arcy Gue


Eleven Areas to Consider in Your ICD-10 Implementation Project Plan

June 2, 2014


ICD-10 4 Minute Read

Since the ICD-10 delay, many providers have been working to readjust their timelines to accommodate the new deadline, October 1, 2015. While the abrupt and unexpected change to the deadline is a source of frustration for some, it is also a relief for many. According to a recent survey, performed by HFMA:

ICD-10 readiness survey results

It seems, looking at these results, that there is a significant difference in the readiness levels of these two groups and hospitals of <100 beds are notably less prepared than larger hospitals.

As we’ve said before, in recent posts, while the delay provides relief, it is important to continue working towards the conversion to ICD-10 with fervor, especially if you fall into the less prepared group, i.e. those hospitals with < 100 beds. With the new timing, providers need to reconsider plans in several areas. In a webinar published a couple of weeks ago, we focused on eleven specific areas to consider when assessing your ICD-10 strategy. It is critical to maintain momentum in the move to the new code set and we recommend reviewing the following areas and re-strategizing in order to ensure a successful transition.

Eleven Areas to Consider When Re-strategizing for ICD-10

1. IT Strategy
Organizations should assess the status of major IT projects. This includes changes in project priorities such as software upgrades and Meaningful Use / MIPS activities. It’s also important to assess the status of your vendors and any new implementations that are in the works.

2. Testing Strategy
The additional year offers more time for industry-wide testing. This includes:

  • Unit testing
  • Integrated testing
  • Testing with clearinghouses
  • Testing with payers

3. Revenue Analysis Strategy
Providers now have time to perform more analysis on the revenue impacts of ICD-10. There are four key steps to performing this type of analysis:

  1. Assess current documentation
  2. Assess ICD-10 coding
  3. Assess the impact of your ICD-10 coding on DRG assignments
  4. Assess the impact of proposed ICD-10 payer reimbursement rates on cash flow

4. Cash Management Strategy
The rush to implement upgrades for MU and ICD-10 will likely cause negative impacts. Mitigate these by using the extra 12 months to reduce unbilled inventory and unresolved claims, optimize upgraded systems and enhance processes, and retain cash prior to October 2015 to prepare for ICD-10 impacts.

5. CDI Strategy
Don’t let your ICD-10 implementation affect Clinical Documentation Improvement efforts. Some recommendations for controlling the affects are:

  • Use revenue analysis outcomes to guide training efforts
  • Impose complete documentation to provide a more realistic foundation for coders
  • Consider documenting using SNOMED terminology

6. Human Resources Strategy
Address the overstaffing that might occur due to the delay by slowing planned hiring. Some providers will choose not to reduce staff — in this case, coders can participate in other activities such as practice coding exercises, performing documentation assessments as part of Clinical Documentation Improvement efforts, or providing quality oversight of existing coding activities. Also consider using coders in physician practices or paying coders a bonus to delay their start date.

7. Contract Strategy
Quickly address contracts for ICD-10 services. Most computer-based training license their content using a yearly model — extending ICD-10 means changing dates of use, extending the length of use, and negotiating contracts.

8. Physician Engagement Strategy
Use the extra year to provide benefits to physicians offices as part of their physician engagement strategies. We recommend:

  • Using under-utilized coders to provide office coding and documentation services
  • Assigning skilled trainers who are already employed to provide training to physician offices
  • Providing additional physician training in documentation
  • Engaging key physicians to assist with EMR and CDI projects

9. Education Strategy
Most facilities have already started the 80 – 120 hours of training required for coders. Hospitals have three ways to proceed:

  1. Complete coder training now and provide coders with the opportunity to code in ICD-10
  2. Complete coder training, but plan refresher training next year
  3. Stop training now and plan to fully train staff in 2015

10. Practice Coding Strategy
It’s important that coders are enabled to continue to practice their ICD-10 coding skills. There are two ways this can be done – Dual coding allows coders to practice ICD-10 coding by using both ICD-9 and ICD-10 codes on a single chart. The second approach is practice coding, which allows coders to code a specific set of charts in ICD-10.

11. ICD-10 Coding and Back Mapping
Use a mapping table to map back to ICD-9 for billing. Many providers who planned to go live with ICD-10 before the 2014 deadline were planning to use this method. Mapping from ICD-10 back to ICD-9 is considerably easier, since there is more specificity in ICD-10. This solution works after a formal transition to ICD-10, because coders don’t have to worry about which payers are not accepting ICD-10 data.

Review these eleven areas and readjust your timeline and plans accordingly. Use the additional year as an opportunity to get the pieces in place for a successful implementation and continue IT and workflow redesign projects at a more manageable pace. It’s important to identify which items should move forward in the near-term and don’t lose momentum.

Over the next few weeks, we will dig deeper into each of these eleven areas to provide detailed guidance on reassessing your ICD-10 strategy.

In the meantime, we recommend that you take thirty minutes to watch our latest webinar that discusses the delay and revising your strategy in detail. You can find the webinar and presentation here.



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