By Jeff Tennant and Kenneth Fody, Esq. for Government Health IT
The delay in ICD-10 implementation was met last week with equal parts relief and frustration. Health plans and healthcare providers who were ready are understandably frustrated by the delay; those that were seriously behind in preparations breathed a deep sigh of relief.
While the ICD-10 mandate is important and the health care industry will benefit from the information these new codes will provide, a deadline that seemed sufficient when it was originally adopted became less so. Numerous other federal and state requirements of equal importance and shorter deadlines were imposed that diverted resources and made meeting the deadline more difficult.
Though most organizations were prepared for conversion, some health plans and some providers were not completely ready. To proceed with implementing the codes on October 1, 2014 date would have resulted in many medical records and claims lacking proper codes and medical documentation. This would have created additional burdens and costs and would not have enabled the industry to achieve the desired goals of the ICD-10 mandate. The harm caused would have fallen largely on doctors and smaller health plans and hospitals.
And, too, there are numerous organizations that have not gone through sufficient testing to be sure their solutions will work as expected. The delay gives those organizations time to test and tune their processes.
CMS should work with industry groups to continue progress
With this new legislation, CMS must adopt a regulation giving a new effective date for the ICD-10 mandate. This likely will be followed by a public comment period and it could be months before the regulation is published and finally approved.
During this process, we’d like to see CMS work with industry groups to identify ways to promote both adoption of ICD-10 and ways to better use the new code sets. Groups that should be consulted include the Workgroup for Electronic Data Interchange (WEDI), the insurance trade associations BCBSA and AHIP, provider organizations such as the AMA and the AHA, and health technology organizations such as HIMSS and AHIMA.
We’d also like to see CMS take two specific actions that will maintain the forward momentum that has come at great cost to many organizations
Milestones to measure progress
First, we’d like CMS to set specific milestones, as they have done when extending HIPAA mandates in the past. The lack of milestones has probably contributed to widespread procrastination.
Setting a date by which both payers and providers must certify their readiness to test ICD-10 or have a defined plan of action to achieve that state of readiness could be a useful milestone. This and other milestones also could provide a better understanding of the industry’s readiness to make the conversion.
Let those who are ready test the new codes
Second, for those who have done the hard work and are ready for conversion, allow willing partners to begin using ICD-10 earlier than the new mandated date. This would have to include specific provisions prohibiting either health plans or providers from coercing or requiring the other party to participate before they are ready. A demonstration project like this could serve as a test of the new codes and would also allow health plans and providers who have invested greatly in preparations to realize the value of their investments sooner.
Make the delay count
We are hearing from several hospitals and health plans that they will continue to work toward an October 2014 launch date. They want to keep up the momentum they’ve built and be ready should CMS decide to allow them to start using the codes on a voluntary basis.
We think that is a smart decision. Here are some specific recommendations for using the delay wisely:
- If you are lagging behind, re-evaluate your plans to take advantage of the delay. Use this time to eliminate short cuts, more fully adopt ICD-10 and allow for more thorough testing.
- If you planned to use crosswalks, re-assess whether these tools are necessary. Use the time to prepare all back end systems to receive and process ICD-10 codes.
- Continue initiatives that have value outside of the code conversion such as improving clinical documentation, coder quality audits, improved reporting and analyses, efforts to better prevent fraud and abuse, improved system and process documentation, and better testing procedures. Even without the adoption of ICD-10 these efforts may provide immediate value.
- Continue and expand testing. Identify business associates and trading partners who are ready for ICD-10 and thoroughly test your systems.
- Do more thorough transition planning. Try to anticipate possible trouble spots and know how you will respond to problems that may arise.
Perform detailed analytics to understand the financial impact of ICD-10 and begin to implement changes in processes and procedures to minimize any negative impact.