ICD-10 Implementation is a journey not necessarily a destination – at least for the foreseeable future.
Remember Y2K? The proverbial sky was predicted to fall. It didn’t. Will the long-anticipated ICD-10 implementation be similarly anticlimactic? Probably not. ICD-10 has been dubbed the “complexification of healthcare” in the Washington Post, which also predicted that “the resulting confusion and inconsistency in claims processing would create unnecessary administrative costs and take resources away from patient care.” Texas Medical Association President, Dr. Tom Garcia, has been quoted as saying, “It’s the countdown to a perfect storm.” Whether the financial firmament will come crashing down on providers’ heads due to ICD-10 will depend not only on their preparations, but what they do after implementation.
It may well prove helpful to consolidate insights, tips and best practices submitted by experts around the country.
Let’s first address the Challenges. Despite all the training and preparation, providers still may encounter the following:
- Productivity decrease. As coders attempt to employ ICD-10, decreasing productivity and inaccuracy-induced delays will have an impact on cost and the bottom line.
- Financial impact. Cash flow disruption from increased denials and underpayment may also occur.
- Resources. You’ve allocated required resources to prepare for implementation. Now it’s time to determine the resources needed to keep the implementation on track.
- Technology-related challenges. These may include data transmission issues and unscheduled vendor updates. You may need to retest critical application or system functionality.
What should you be doing?
- Create, implement, assess, and continuously correct a post ICD-10 implementation strategy. Take into account that this has not only impacted procedures, policies, and skill sets, but also people—including employee morale. Any change is threatening until employees can acknowledge what practices they need to let go of, deal with the sense of loss of the familiar, can understand and envision what ICD-10 competency can do for the organization and for them personally, and fully embrace the new best practices and skill sets. Tip: Involve your staff in troubleshooting through problem and resolution identification.
- Assess demands on resources. Address effective allocation of the most impacted resources.
- Set goals from the top down and the bottom up. Setting goals goes hand-in-hand with tracking key metrics. Involving ICD-10 stakeholders at all levels within your organization is critical.
- Monitor net revenue and cash trends. Identify, understand, and mitigate the root cause(s) of any cash flow disruptions or revenue declines.
- Assess documentation quality. Experts emphasize the need for specificity in clinical documentation.
- Prepare to defend code assignments. Make sure that the documentation is consistent with the ICD-10 coding demands and supports the classification information details. Notwithstanding their inherent differences, learning a coding/classification system and understanding the clinical factors of a diagnosis are related…and important. Tip: Audit coding productivity and accuracy.
- Training, training, and more training. Training will never stop. Tip: Develop a formalized on-going training program for clinicians and coders.
- Hire coding help in the short run. Experts can help you assess where you are by conducting audits and working closely with coders and clinicians alike.
- Review the Q&A document before submitting claims and MDS assessments that include October 2015 dates of service (include SNF clinicians, MDS coordinators, and billers in the review process)
- Track key preparation and processing metrics. Rome wasn’t built in a day...nor will your process be built over night. If you have not already done so, identify key preparation and processing metrics and track them. Set benchmarks for the near and long term.
- Acknowledge that it's an on-going process and accept it.
Taking steps throughout the ICD-10 implementation process will prevent the cash flow and bottom line storms from raining on your financial parade. Several resources are available to help you make the transition to ICD-10 successful. For example:
Additional thoughts from CMS
The Centers for Medicare and Medicaid Services have recently offered the following:
- The ICD-10 Ombudsman will be available to help answer nursing facility questions and can be reached at ICD10_Ombudsman@cms.hhs.gov.
- Minimum Data Set (MDS) assessments with Assessment Reference Dates (ARDs) on or before September 30, 2015 must contain a valid ICD-9 code in Section I if a diagnosis code is necessary. SNF MDS assessments with ARDs on or after October 1, 2015 must contain a valid ICD-10 code. CMS will reject MDS assessments if a Section I diagnosis code version does not apply for the ARD entered.