Twelve Steps for ICD-10 Implementation at Physician Practices

10. Address policy change development. Do you have contracts with Medicare Advantage plans or other health plans that base payments on patient severity of illness? For example, Medicare uses beneficiaries' characteristics (e.g., age and prior health conditions) in its CMS–hierarchical condition category risk adjustment model. The model uses ICD-9-CM diagnoses to predict expected resource utilization for each beneficiary. Medicare Advantage plans benefit from higher capitated payments when their covered lives are deemed high risk. There may be some new opportunities to appropriately improve payment with ICD-10 coding, which may better reflect your group's patient severity of illness.

11. Test the system (i.e., the deployment of the codes). Seek assistance from your vendor to do this. Make sure there is adequate time to perform the testing and allow for necessary internal customizations. The vendor should ensure that updates will be maintained during transition.

12. Track implementation compliance. Monitor all activities to identify potential problems after the implementation is complete. If payments are reduced or slower than usual, investigate whether the problems are related to a certain payer or are general in nature. A general slowdown could indicate that the problem is related to the practice's processes. Ask the following questions to track implementation compliance:

• Are superbills used consistently and appropriately?
• Are coders able to choose the correct diagnoses in a timely manner?
• Are there delays in getting the claims final billed?
• Do explanations of benefits indicate denials that were not present before the conversion to ICD-10-CM? Track what payers deny to determine whether there is a pattern to the denials.
• Are other practices that use the same vendors or clearinghouses having the same problems?