More than a month and a half after President Obama signed the ICD-10 delay into law, CMS still lists October 1, 2014 as the ICD-10 compliance date on most of its websites and educational materials. The delay may have taken the agency (and most of the industry) by surprise, but the glacial pace of adjustment has left providers wondering what they should be doing as the timeline stretches on. How can organizations keep moving forward towards ICD-10 compliance while eliminating the possibility of financial waste, technical glitches, and educational disasters?
Taking advantage of CMS resources
CMS hasn’t been entirely idle during the past six weeks. After taking some time to reevaluate their position, the agency has set the official compliance date for October 1, 2015 and decided to cancel its planned end-to-end testing pilot formally slated for July. While only one of these seems like a positive step, CMS will be ramping up its series of educational provider calls again as it scrambles to write up the interim final rule, with the first session set for June 4.
Additionally, the resources released over the past year aren’t entirely useless, even if the date hasn’t been changed yet. The basic steps towards implementation are the same, and thedetailed checklists can help providers puzzle out what they still need to accomplish as they fine tune their individual organizational plans.
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Revamping the coding roadmap
The bigger challenge will be fitting the remaining implementation steps into the new timeline. While many organizations have expressed a desire to push ahead with their original ICD-10 plans regardless of the go-live date, language from CMS may put the kibosh on voluntarily using ICD-10 for billing purposes before October 2015.
Still, the extra time gives providers a chance to work dual coding into their plans. With last October’s National ICD-10 Pilot producing “scary” and dismal results in relation to worker productivity and coding accuracy, investing in dual coding may reap significant rewards. Even physicians may want to take the opportunity to learn a little bit more about ICD-10 than they had planned in order to bolster their understanding of the changes involved in their documentation and workflow habits.
Dual coding may also help organizations with their current billing programs, adds Mel Tully, MSN, CCDS, CDIP, Senior Vice President of Clinical Services and Education at Nuance. “If you have a mediocre program in ICD-9, you’ll have a mediocre program in ICD-10, so it’s time to make those changes, hire appropriately, getting the right people in line,” she said. “And then, also make sure that you have the tools and the software so that the documentation specialists can actually start practicing and be successful.”
Strengthening ties between business partners
Providers have never worked in isolation when it comes to ICD-10 implementation, no matter what the compliance date happened to be at the moment. The additional months may be a boon for vendors who didn’t know if they could get their products delivered on time, and will also provide more of an opportunity for industry-wide, end-to-end testing, regardless of what Medicare testing programs CMS may or may not put into place in 2014 and 2015.
Hospitals largely doubted the ability of payers and providers to be ready for the October 1, 2014 date, so now is the chance for organizations to prove them wrong. “With the extra time after the delay, some payers may be looking at different technical solutions and additional options, which is probably a good thing,” said Erik Newlin, Co-chair of the ICD-10 Assessment Workgroup at WEDI and Director of National Standards Consulting at Xerox. “They might be able to do more robust translational activities and have more time to test in ways that maybe they wouldn’t have prior. And so perhaps we’ll have fewer issues on the back end.”
It’s the provider’s job to reach out to those payers, understand their new plans, and volunteer for testing arrangements that may help ease the passage into ICD-10 come next fall. Participating in end-to-end testing as early as possible can help to mitigate some of the financial impacts of the delay, which are poised to strike every stakeholder in the industry if momentum grinds to a halt.
“The providers and payers depend on each other completely for this process,” Newlin adds. “The payers are limited by the time they have to fix the issues they encounter. The providers need to be able to create accurate, complete claims in ICD-10. And if providers are unable to successfully test with their payers, or if the providers aren’t producing enough different types to test appropriately with the payers, neither party is going to benefit as much as they could from the extra time.”
Pushing on with clinical documentation improvement
Clinical documentation improvement (CDI) has benefits that go far beyond ICD-10, but the major push towards better notes has come from the new requirements presented by the code set. “Detail and specificity” may be a phrase that physicians are tired of hearing, but until they have achieved the level of granularity in their documentation that allows coders to do their jobs appropriately, they’ll keep hearing it long after October 1, 2015.
The delay will give educators a chance to reinforce these new rules while bulking up training that may have been pushed off due to the technical challenges of the switch. “We feel that physicians should be educated from a clinical perspective, not a coding perspective,” Tully said. “The minute that you start showing them codes, they say, ‘Oh, I’m not going to remember this. I don’t want to be a coder.’”
“So when we talk to physicians, we say, ‘Here, please tell us clinically the information that we need to be able to code it in ICD-10.’ This is where it’s very important that the documentation specialists realize what is the clinical threshold for this particular diagnoses, and what specificity is required, and let them actually interact with physicians in a concurrent fashion or, hopefully, real-time with technology, supporting that real-time interaction in the future.”
Date: May 19, 2014