Industry experts have repeatedly said that ICD-10 implementation must begin immediately in order for hospitals, health plans, and vendors to meet the October 1, 2013 compliance deadline. But now there is detailed evidence to prove it.
On July 20, the North Carolina Healthcare Information and Communications Alliance, Inc., (NCHICA) and The Workgroup for Electronic Data Interchange (WEDI) released a timeline that quantifies each ICD-10 preparation task in terms of the number of days it will take to complete.
NCHICA and WEDI estimate it will take providers nearly 1,286 work days to implement ICD-10. For vendors, it will take nearly 1,521 work days to complete. And the clock is ticking.
"The NCHICA-WEDI timeline shows graphically that the full time from now to October 2013 will be required to successfully meet the compliance deadline. We cannot continue to delay this effort," said Holt Anderson, executive director of NCHICA in a press release.
For providers, the figure takes into account 256 days to organize the implementation effort. The timeline also outlines 36 months for identifying process improvements (e.g., how hospitals intend to use more specific data to target education or treatment for certain patient populations), 14 months for internal system design/development, 12 months for internal testing, 12 months for vendor code deployment, and 10 months for external testing.
Although the numbers may sound daunting, the writing has definitely been on the wall since CMS' January 16, 2009 publication of the ICD-10 final rule. Hospitals should already be well on their way toward planning for the change.
Hospitals need to realize that adopting ICD-10 isn't a choice and that there won't be any extension or contingency period in which to do so, says Stanley Nachimson, principal of Nachimson Advisors in Reisterstown, MD, and director of the NCHICA and WEDI timeline project.
Failing to comply by the 2013 deadline or to perform adequate internal and external testing could result in delayed or denied reimbursement, Nachimson says, adding that certain delays and problems will be unavoidable. "There may be a period of time where claims are slowed down while everybody gets used to the coding and understands it," he says.
These delays are something that nobody wants to think about right now, Nachimson says. "Hospitals have such thin margins these days. Even a 1% interruption in their cash flow may be very difficult to manage," he adds.
Managing an ICD-10 implementation among other larger and costly initiatives is also challenging, says Shereen Martin, RHIA, MSA, director of HIM and privacy officer for Washington County Hospital in Hagerstown, MD. Many hospitals nationwide will be focusing their efforts on recovery audit contractors, leaving few resources to devote to ICD-10, she adds.
Washington County Hospital is currently in the midst of deploying an EHR in its ED, implementing computerized physician order entry, and preparing for complex RAC reviews in August. As with most other hospitals, Washington County must first determine how it will fare with RACs before deciding how soon it will turn its attention to ICD-10, she says. "Coding managers will be dealing with both issues [RACs and ICD-10]."
Starting as early as you can—particularly from a budgeting perspective—will only help you in the long run, Nachimson says. "If you want to get this done, you need to do some of it now and some of it in each of the next few years," he adds. "Otherwise, you're going to get to 2012 and be faced with such a large resource or budget need that you're not going to be able to make it."
As hospitals begin to think about how to qualify for EHR incentives under ARRA, they also need to be asking how vendors plan to accommodate ICD-10. Hold vendor representatives responsible for their own portion of the timeline, Nachimson says.
Although vendors may be able to provide some education, hospitals need to think about how ICD-10 will affect their business processes. For example, how will hospitals ensure that physician documentation will be specific enough to meet ICD-10 standards? How might quality measures or clinical guidelines change to accommodate the new codes? Will health plan coverage for certain tests change so that only certain severe conditions will be deemed medically necessary? These questions are only the tip of the iceberg in terms of potential ramifications of ICD-10, Nachimson says.