The publication of the final rule officially announcing a change in the ICD-10 compliance date from October 1, 2013 to October 1, 2014, ends the uncertainty surrounding ICD-10 implementation that has plagued the healthcare industry.
The Department of Health and Human Services (HHS) based the decision to move forward with a one-year delay on the conclusion that a significant number of healthcare entities would not be prepared to meet the original compliance date.
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As HHS noted, it is crucial that all segments of the healthcare industry transition to ICD-10 at the same time. The failure of any one industry segment to successfully implement ICD-10 has the potential to affect all other industry segments. Such failure could ultimately result in returned claims and provider payment delays that disrupt provider operations and negatively impact patient access to care.
Don’t expect another delay
It would be extremely ill-advised for a healthcare organization to count on another delay.
After careful, thoughtful consideration, HHS decided a one-year delay minimized the costs of delay while maximizing the benefits to providers who need more time for implementation. HHS clearly recognizes and acknowledged in the final rule that further delay would seriously disrupt ICD-10 transition efforts and significantly increase conversion costs.
Many healthcare entities have invested significant resources preparing for the transition. A one-year delay will cost an estimated additional 10%-30% on top of the amount commercial health plans and large providers have budgeted for the ICD-10 transition.
A two-year delay would be at least double the additional cost of a one-year delay, and the costs would continue to mount for every additional year. In addition, the healthcare industry suffers opportunity costs each year that the US fails to implement ICD-10.
Get implementation back on track
Therefore, healthcare organizations that may have stopped or slowed their ICD-10 preparations after HHS first announced its intent to consider a delay need to get back on track with renewed vigor. Those organizations that did not suffer a loss of momentum need to forge ahead.
Organizations will need to adjust their ICD-10 timelines and budgets to account for the change in compliance date. It’s important to ensure the organization’s implementation timeline includes time for adequate internal and external testing. Also, organizations will need to reevaluate ICD-10 planning and determine how preparation affects the organization’s other projects and priorities. They will also need to adjust timelines and budgets to make the best use of available time and resources.
Working on ICD-10 in tandem with other related initiatives can potentially minimize duplication of work and reduce costs.
Your organization should have completed initial ICD-10 implementation plans and impact assessments by now. Organizations should now begin to implement systems and business process changes identified during the impact assessment.
Organizations should also be implementing systems and business process changes, and modifying policies/procedures, reports, and forms.
Training for data users (such as quality management personnel, data analysts, researchers, clinical department managers) should be in process. Organizations should now assess coders’ knowledge gaps and determine whether foundational education on biomedical sciences and pharmacology is necessary. Coder should continue to expand their familiarity with the ICD-10 code sets.
Coders who will be involved in ICD-10 implementation projects (such as data mapping or training other coders) should have received intensive ICD-10 training by now. If the training has yet to take place, schedule it soon.
Be sure you assess the quality of record documentation and implement clinical documentation improvement strategies to address gaps. This process will continue past the Oct. 1, 2014 compliance date.
Your organization can facilitate proper documentation through the use of electronic health record documentation templates and prompts. This approach will not only result in better documentation, but also greater coding accuracy and productivity and improved coder and physician satisfaction.
High-quality documentation benefits not only the quality of ICD-10 coding, but also many other current and future healthcare initiatives, including quality measurement reporting, value-based purchasing, and the Meaningful Use program. If your organizations is not where it should be with ICD-10 planning and preparation, there is no time to waste.
A one-year delay is not a “reprieve” from working on ICD-10 planning and preparation. No healthcare entity should be lulled into thinking that a one-year delay means it can relax its pace of ICD-10 implementation efforts, or set aside ICD-10 until later.
As organizations that are deep in the throes of ICD-10 transition preparation have discovered, the scope and complexity of the ICD-10 transition are significant. No matter how much time organizations think they have, or how far along in ICD-10 preparation they think they are, there is isstill has plenty of work to complete by October 1, 2014. And the longer organizations delay getting started, the greater the risk of non-compliance and the higher the cost to remediate.
Take advantage of the transition
The ICD-10 transition offers a unique opportunity to assess operations and make improvements that lead to better and more efficient processes and workflows. You can use this time to mitigate pPotential problems through proper planning and preparation.
Entities that were not on schedule to meet the original 2013 compliance date have a “second chance” to not only be prepared to meet the new compliance date, but to move beyond mere compliance to leverage their ICD-10 investment to achieve strategic value.
Transitioning to ICD-10 smoothly and on time requires the engagement of strong executive leadership support and sponsorship and dedication of adequate resources. If senior leaders don’t consider ICD-10 a high priority, or commit the necessary staff and other resources to this project, other levels of the organization won’t either.
Healthcare entities that are on track with the original compliance date can use the extra time to:
- Conduct more thorough testing
- Provide additional training
- Continue to communicate with trading partners regarding their readiness
- Assess risks
- Develop strategies to mitigate risks and maximize opportunities for success
Examples of risk mitigation strategies include:
- Using innovative approaches to staffing and education
- Leveraging available resources
- Ensuring the right training is provided to the right people at the right time
- Planning for post-implementation monitoring
Entities on schedule to meet the original compliance date should consider maintaining their current implementation preparation schedule and planning and use the additional time for expanded testing.
Those organizations that are well ahead of schedule could extend ICD-10 education and outreach activities to other healthcare entities in their communities that are struggling to meet the 2014 compliance date.
Collaborative efforts across the public and private sectors can help to ensure all industry segments are ready to transition to ICD-10 on October 1, 2014. As noted earlier, all industry segments will suffer if some sectors are not ready.