The Department of Health and Human Services has insisted it will not budge on its October 1, 2014, implementation date for ICD-10. Nevertheless, surveys indicate painstakingly slow progress among hospitals and health systems. Experts stress it’s time to get rolling.
According to a survey of 120 hospitals with 400 or fewer beds surveyed by Health Revenue Assurance Holdings, approximately half are not following official Centers for Medicare & Medicaid Services (CMS) timelines on preparing for the ICD-10 transition. Twenty percent of these smaller hospitals have not begun any ICD-10 training or education. Forty-seven percent have not begun documentation improvement education for their medical staff and 31 percent do not plan to dual code prior to the implementation date.
The 2013 ICD-10 readiness survey conducted by Workgroup for Electronic Data Interchange (WEDI) also indicates slow progress among healthcare stakeholders, including providers, vendors and health plans. The survey, conducted by Nachimson Advisors, was voluntary and likely “represents a more advanced group than the general population, so the results should be interpreted carefully,” according to Stanley Nachimson, of Nachimson Advisors and former CMS lead on HIPAA regulatory development and implementation.
Unfortunately, this more advanced group isn’t meeting recommended implementation timeline milestones either. Findings indicate approximately 40 percent of hospitals have completed their ICD-10 impact assessment and 40 percent said their completion date is unknown. When asked for their expected date to begin external testing with health plans and trading partners, half said unknown and 33 percent expect to begin sometime in 2014. That means many providers will have less than nine months for external testing and may not have considered the need for extensive testing, Nachimson said. That abbreviated timeframe might not allow for enough testing “to prevent major disruptions upon compliance.”
There has been minor progress in vendor solution development, according to the survey findings. About 20 percent of the plans surveyed said their ICD-10 services and software are now available to customers and about one-third will be ready in 2013.
About half of health plans had completed their formal impact assessment gap analysis and another quarter said they were nearing completion. About three-quarters plan to start internal testing of fully functional ICD-10 processing sometime in 2013. Start dates for external testing were split—with half saying they will begin prior to January 1, 2014. That means half of health plans will have nine months or less to test with trading partners.
Prepare for change
Jim Daley, WEDI chairman, cites issues that arose during the transition to version 5010 electronic administrative transactions last year because people didn’t adequately test. Version 5010 primarily presented formatting changes with some content changes. “With ICD-10, the content within them is changing very significantly,” he says. “If we had a small amount of problems with 5010, just think of the potential magnitude of problems with ICD-10 with diagnosis and procedure codes changing so dramatically.”
Daley recommended developing baseline metrics now, so, upon implementation, providers can look for changes and determine whether they are predictable changes or issues that needs some remediation.
Nachimson recommended measuring factors such as how long it takes to get a claim out the door after a visit, the distribution of codes by specialty and accounts receivable days to “get a sense of what’s going to happen after October 1, 2014.” One change is certain: claims with ICD-9 codes submitted after that date will be returned to providers as unprocessable and not paid.
By knowing every point that diagnosis and procedure codes or some derivation are used, Daley says, providers can put appropriate training in place so people understand how to use new processes or codes.
The October 1, 2014, implementation date “is firm. The time to transition is now,” says Denesecia Green of the Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services. “We are asking everyone from now until the end of year to start internal testing to ensure that you have all pieces in place,” Green urged during a recent webinar presented by the agency.
She also advised providers that ICD-10 can’t be executed on the 4010 platform. “You have to convert to ICD-10. Clearinghouses won’t be able to convert 4010 ICD-9 claims to ICD-10. Start conversations with vendors to ensure the proper systems are in place.”
Speaking during the 2013 Health Information Management & Systems Society annual convention, Susan Trewhella, associate vice president of revenue management for Geisinger Health System, detailed the organization’s ICD-10 efforts to date.
Danville, Pa.-based Geisinger conducted an enterprise-wide impact assessment in spring 2011 to understand the key risks and opportunities and then established an ICD-10 inter-disciplinary working committee with leaders that represent each functional area. Working with a consulting firm, these functional leads facilitated working sessions with more than 200 participants from key functional areas.
Geisinger’s highest volume code is hypertension so “we ran a detailed report through the physicians to identify which would need the most training,” Trewhella said. Since physicians are the coders in many office practices, they worked to determine how and which ICD-10 codes to present to them.
Through its assessment efforts, Geisinger learned that 80 systems will be impacted by ICD-10, she said. The IT department is maintaining a list of all systems and keeping in touch with vendors on their readiness. They ask vendors for their plans and when they will have the ability to test. “If they don’t have a good answer, they might not remain a Geisinger vendor,” she said.
Today, Geisinger is in the process of designing and constructing workflows and preparing to start advanced training. Other providers would be wise to follow suit—sooner rather than later.