Time is Ticking: ICD-10 Implementation

ICD-10 has been a thorn in the side of the healthcare industry for years now. But, after a one-year delay, the federal government has declared there will be no further extensions beyond the Oct. 1, 2014, implementation date. With the more extensive coding system impacting so many aspects of healthcare, experts agree: start now.

The ICD-10 National Pilot Project, which ran from April to July, tested use cases which will be published in the HIMSS ICD-10 Playbook. The use cases and test report will be available to all, says Lisa A. Gallagher, HIMSS vice president of technology solutions.

“The testing process we set up was meant to be collaborative. If there were any challenges with any individual test, both parties worked on a solution,” she says. The project report will include advice on testing and methods for ensuring that coding is done properly.

In general, hospitals are pretty well prepared but Gallagher has heard anecdotally that smaller providers are struggling and payers are working on their preparation efforts as well. It’s difficult to reach small providers “and harder to pull them into the process when they’re busy treating patients.” HIMSS’ role is to educate and provide resources and hopes to meet that goal in part with its ICD-10 playbook which will include data from all over the industry to try to meet everyone’s needs.

Assessing & mitigating

New York Presbyterian Hospital (NYP) in New York City got involved in the pilot project early because it “offered the opportunity to collaborate with the different partners we need to collaborate with in a very pragmatic way at an industry level,” says Jason A. Gottlieb, director of ICD-10 implementation.

“At the time we joined, which was pretty early, there were still a lot of unknowns with payers, vendors, clearinghouses and other organizations. We wanted to mitigate our risk.”
The facility won’t be participating in the testing program. The organization has been able to establish proprietary testing directly with its payers, claims processing vendors and clearinghouse. “There doesn’t seem to be a real benefit in directing our coding efforts towards that program when we can do it internally and directly with individual payers we contract with.” Gottlieb says smaller hospitals struggling to establish partnerships with payers would find more benefit in participating.

NYP has the infrastructure to sustain the impact of ICD-10, says Gottlieb, as well as a robust documentation improvement program that coordinates documentation activity with the physicians, a fairly robust EMR and computer-assisted coding. “We have a lot of things other organization don’t. If you don’t have those things, the impact will be much more significant. We don’t believe from a reimbursement standpoint that we’re at massive risk. We think that ICD-10 will be an opportunity for us. Any financial impact will be on the positive.”

The organization has taken several steps to mitigate the risk around ICD-10. “We’re trying to make our documentation improvement efforts more concurrent with patient care,” Gottlieb says. “We have shifted our focus to get our nurses up on the floor while patients are still in house.”

NYP also integrated documentation improvement efforts at the service line level to educate physicians about the documentation practices that are going to have to change or become more specific because of ICD-10. Specific documentation changes should be enough to address ICD-10 for most clinicians, Gottlieb says. “Don’t run around the organization saying that physicians have to know ICD-10 because they don’t.”

Addressing ambiguities

The Hospital for Special Surgery in New York City also participated in the National ICD-10 Pilot Project as part of the coding workgroup. The facility’s coders took sample cases, removed all protected health information (PHI) and coded them in ICD-9 and ICD-10, says Roberta Bosanko, MS, senior director of finance and ICD-10. Other coders in the workgroup coded and validated the cases, which will serve as the eventual code set. “The process exposed some areas where further guidance is needed.”

Bosanko says the exercise has been beneficial because it allows for resolution of ambiguities before the implementation date.

Meanwhile, “we’re doing everything we can to be prepared and take advantage of the additional year for end-to-end testing, education, gap assessment and coder knowledge,” Bosanko says.

Collaborative planning

ICD-10 is the perfect challenge for the Massachusetts Health Data Consortium (MHDC) to address because the organization was established in 1978 specifically “to address data and information technology where collaboration is much more effective than going it alone,” says Denny Brennan, executive director.

MHDC members asked for a consortium-based ICD-10 collaboration. “There is no competitive advantage in being good at ICD-10. Everybody needs to be on the new code set,” says Brennan.

Stakeholders across Massachusetts are working very hard to prepare for ICD-10, Brennan says. Providers are engaged in preparedness and planning efforts and “are in various stages of testing the impact of these new codes on their internal systems and communicating actively with their trading partners to understand how to be ready and how ready their partners will be. I’m impressed with the progress.”

One challenge MDHC is addressing is figuring out “how to clear out some of the noise in the system. There is a lot of anxiety. Changes don’t come without the attendant anxiety so we’re working on how to focus on the critical steps everyone needs to take to get to October of next year,” he adds.

There has been some fear-mongering about the industry being behind schedule in its preparations, Brennan acknowledges, but organizations can’t be ready until the actual implementation date. “You have to be ready right on time” and Bay State organizations are working on testing, operational readiness, workforce planning, training and development, communications and more. “They are working within their own shops but also coming to our meetings and workgroups to actively work together and make sure they don’t reinvent the wheel.”

MHDC anticipates that most organizations will spend the bulk of 2014 on testing but they have to get their own house in order first, Brennan says. “They have to be ready to accept and process these codes. They should organize and collaborate around testing if they expect to have greater assurance that the transactions are going to work.”

Variables & resources

A great challenge of ICD-10, Brennan says, is the high number of variables. His team has gotten dozens of calls from providers seeking help with their testing transactions but each is unique. That’s why the collaborative testing model that will create virtual end-to-end testing is the best method for assurance in the time remaining, Brennan says. MHDC also seeks to make sure its members are not setting up redundant and duplicative testing environments. The organization is helping organizations prepare internally with training, documentation improvement, policy and business redesign. “There are a lot of things ICD-10 touches.”

Other resources may soon become hard to find. “People are trying to hire ICD-10 project managers and coders—the demand has ballooned,” says Brennan. “We’re seeing a shortage in the marketplace now. If you wait too long, resources won’t be available and you won’t have given yourself enough time to develop those resources yourself.”

HIMSS’ Gallagher says outside resources are available. “It’s more a question of organizations putting a plan in place and executing it. You can’t wait until the last minute or no one will be available to help. Work on it now.”

Gottlieb says he is confident healthcare will be ready for ICD-10 next October. “Ready is going to be this word that ends up in quotations. I think that people will have no choice but to be ready but …what kind of problems originate as a result of having to be ready by Oct. 1, 2014, are yet to be determined.”

Bosanko echoes the advice to get started. “Don’t waste a single day. Take advantage of the time you have now and dedicate all the resources necessary. An ounce of prevention is worth a pound of cure.” She compares ICD-10 preparation to an onion. “The more layers I peel back, the more issues I find to cry about—things you didn’t even think to think about and you won’t know that until you’re in the remediation process.”

Hopefully, adequate planning and processes will staunch the flow of tears.