ICD-10 planning is not a sprint, but 'get started'

“Get planning,” said Sira Cormier, MBA, principal of CSC which operates the New England Healthcare Exchange Network (NEHEN). “ICD-10 is not just an IT problem. Everybody needs to be involved in the planning.” Cormier and her coworker spoke during the Massachusetts Health Data Consortium’s forum on ICD-10 on Dec. 13.

There are several reasons to invest in strategic and comprehensive ICD-10 testing, she said, including financial exposure, transition readiness and relational risk. Consider the impact on your call center. Payers will be getting a lot more calls which means providers will as well. “It’s not just about systems working well together it’s about processes of the people. If ICD-10 doesn’t work well, all relationships could suffer.”

When coders receive clinicians’ notes, they will probably have questions for those clinicians. “It may take a couple of times to get the coding correct.” And even when finalized, there may be coding errors, she said. The process takes a couple of days now but may take seven to 10 days with ICD-10. Discharge to final bill time is going to increase. Accounts receivable is going to go up and claims in pending status will go up. But, “the more you do around testing, the better prepared you’ll be. It’s inevitable that in the first weeks and months, there will be an increase in rejects and denials, cash flow interruption and a negative revenue impact.”

“If you haven’t started yet you’re not alone," said Lisa Kreeger, RN, Phd, principal at NEHEN. Organizations self-assess their readiness at a higher level than reality, however. According to an IDC Health Insights ICD-10 conversion study, less than half of organizations have initiated any ICD-10 testing, said Kreeger. Health plans are ahead of care delivery organizations but most have not defined an overall strategy with testing timelines.

Governance is critical. “We’ve seen projects fall down around this,” Kreeger said. “People have different ideas of what it means to trust someone else. Those differences are relationship breakers. Conversations happen within and outside organizations and before you know it your governance isn’t working.” It takes time for people to work out what they mean by trust and collaboration and the extent of disclosure necessary. “We’re all committed to reaping the benefits of ICD-10 codes, but it’s such a complex thing.”

Each organization has to decide how to handle education, training and testing. Lots of organizations have the resources and acumen to develop their own tools, Kreeger said, but there are lots of ICD-10 tools for sale as well. Each organization has to determine the best balance. “It doesn’t have to be either or. You can hand-select a combination based on external accelerators and internal expertise.”

“With ICD-10, the devil is in the details,” Kreeger said. “Your risk might be in system integration with a vendor.” The day’s speakers returned repeatedly to the idea of collaboration but she said, “as much as you collaborate, keep an eye on your unique interests.”

Waves of testing provide the opportunity to make business decisions. That will be important, Kreeger said, because there are not enough service companies to go around. “We can’t all do our Christmas shopping on December 24.”

Competition could happen internally as well. Competing priorities fight for budget, resources and perhaps “IT bandwidth in terms of the ability to set up a parallel testing environment, Kreeger said. “As remediation goes along, as you’re doing early internal testing, you may end up needing to set up multiple iterations of your internal testing environment.” Another consideration is the extent to which you will conduct external testing, she said. The depth of trading partner validation can be a simple yes or no answer or go all the way to payment neutrality. However deep the testing, organizations need to prepare for a lot of work. “Don’t believe anyone who says any aspect of this can be automated. It’s always going to involve people and time.”

Mapping is absolutely foundational to testing, Kreeger said. “We suggest cross disciplinary mapping teams. We have seen organizations underestimate the need for peer review for not only issues like distinguishing between the letter o and the number zero but the clinical expressions meant by the ICD-10 codes.”

Change control can be the most difficult piece of all, she sad. Even once maps are created, “you can’t claim victory because policy, edits and more will all change. The minute you’re done it’s all obsolete. You need to know what version of documents you mapped from.” She suggested finding technology-enabled ways to quickly do change control because it’s easy to underscope.

It’s easy to be nervous about ICD-10, Kreeger said, but get started. “It’s not a sprint.”