ICD-10 is Delayed: What Should You Do?

Amy Morrow Vanessa RaffioPositive and Negative Impacts

Amy Morrow, Senior Consultant, Santa Rosa Consulting
Vanessa Raffio, Senior Consultant, Santa Rosa Consulting
Twitter: @SantaRosaHealth

You’re driving to the airport on a beautiful sunny day to catch your vacation flight. You’ve packed your bag, the weather is great, you check-in without incident, breeze through security, and are feeling like everything is going as planned. Then, you’re about to board your plane and they announce you’ve been delayed. That’s what just happened in the ICD-10 world.

While not everyone was shocked by this development, those of us who have been immersed in ICD-10 were quite surprised at how quickly it occurred and where the delay came from. As we wait for CMS to post official details on the revised timeline for ICD-10 compliance (and on the details of exactly how this transpired!), there are some important considerations for your organization to keep momentum moving forward.

Organizational Readiness

  • If you’re one of the organizations relieved to hear this announcement because little has been done to prepare, you now have an opportunity to make ICD-10 a success. Take advantage of the delay and work to make sure your organization can successfully transition to ICD-10.
  • Form an ICD-10 Steering Committee, if you have not already, and ensure you’re meeting regularly to prepare for ICD-10.

Operations Assessment

  • If your organization has not already participated in a deep dive operations assessment to identify all processes, departments, and entities interacting with ICD codes, now is the time to take advantage of the time delay and ensure this is completed.
  • Look for issues that had been identified as problematic currently and also for ICD-10 and work on them now with the help of the Steering Committee and work groups – for example, medical necessity write-offs, denials, and quality coding in physician practices.

Technical Migration

  • Continue to communicate with vendors and strategize for any upgrades required to achieve ICD-10 compliance. The vendors we’ve contacted since the announcement are all still moving forward, taking advantage of the time delay to make sure their approach is the best possible given the changed timeline.
  • Ensure any processes, software, or technology already ready for ICD-10 can continue to utilize ICD-9 codes after 10/1/14.

Training & Education

  • Begin or sustain physician documentation improvement training and work on getting providers documenting with ICD-10 specificity now.
  • Begin or continue coder training to ensure coders are adequately prepared and have sufficient time for dual coding.
  • Consider whether you have time now to design programs to ‘train your own coders’ – i.e., internal staff who would welcome the enhanced job possibilities and reduce reliance on outsourced solutions in the future.

Clinical Documentation

  • Review plans for Computer Assisted Coding. If you were delaying implementation but had picked a vendor, maybe there is time to get started. It’s still an aggressive timeline to implement prior to Fall of 2015, but it is an improvement over trying to implement prior to 10/1/14.
  • Focus on getting all physicians completely live on electronic documentation and design documentation templates to help them achieve appropriate ICD-10 specificity.
  • Engage your CDI department in physician education, query, and template design.

Financial Planning

  • Assess impacts of the ICD-10 delay to your budget.
  • Use this time to focus on eliminating the assumed issues with reimbursement we were all anticipating with the October 1, 2014 transition – more testing, more training for claims review staff, more focus on current workflows in the revenue cycle process.

Implementation Planning

  • Create/update your project plan. Ensure no momentum is lost (many of us remember how we spent our last one year delay!).
  • If a project manager is not in place, assign or recruit one to keep you on target and possibly incorporate some of the new ‘optimal solutions’ you identified in the steps above. Remain vigilant for potential updates or new codes from CMS for this October timeframe; remember we have not received new ICD-9 codes or grouper updates since 2012.

There are positive and negative impacts as a result of the ICD-10 delay, but it is critical that organizations sustain what has already been done and avoid having to do it all over again. Like our planned vacation and plane status issues, we wouldn’t just cancel a vacation because of the flight delay, we’d come up with an alternative solution.

If your organization could benefit from ICD-10 planning, project management, or an Assessment, please contact Santa Rosa Consulting to discuss how we can assist. We want you to arrive at your revised deadline ready to enjoy the experience!

About the authors:  Amy Morrow is a Senior Consultant at Santa Rosa consulting with over 14 years of Revenue Cycle experience. Amy has spent over a year focused exclusively on ICD-10 and helping her clients prepare for ICD-10 transition. She also has experience as a Revenue Cycle Analysts and has knowledge of CMS billing rules.

Vanessa Raffio is a Senior Consultant at Santa Rosa consulting with over 11 years of experience in the healthcare industry. Vanessa has extensive experience in practice management, as well as over 6 years as an Epic HIM and Ambulatory analyst and project manager. For the last 6 months, Vanessa has been focused on assisting organizations with assessing their ICD-10 readiness and preparing for the transition from ICD-9.

This article was originally published on Santa Rosa Consulting and is republished here with permission.