The march to ICD-10 is upon us again. You have heard it from the leadership at CMS before: “this is THE year (2013, 2014) we’re really going to make the change to ICD-10.” And each year the mandate upon all HIPAA covered entities in the US, has been delayed in the US Congress, typically at the last minute. This has caused many vendors, payers and providers to delay their own efforts around the transition to the international standard for diagnosis coding, which many believe reflects a more granular approach to documentation leading to better public health, cost control and standardization.
ICD-10 is not without its detractors as well. Accommodating an increase of over 50,000 diagnosis codes is a massive undertaking and many high-profile organizations representing providers have expressed staunch opposition to the mandate, questioning the value of ICD-10 and expressing grave concerns about the impact of delayed or lost payments due to ICD-10 coding errors.
Sense Corp clients are preparing for the change and our team has been busy leading up to the deadline, but this uncertainty has impacted the broader industry. A recent survey by the Workgroup for Electronic Data Exchange (WEDI) suggests that readiness for ICD-10 is still lagging:
- Health plans: A little more than 50 percent of health plans have begun external testing, and of these, a few have completed testing. This is the bright spot of the survey as it represents a slight improvement from the prior survey in August 2014
- Vendors: About 60 percent of the vendors indicated their products were available or they had started customer testing. This is a slight decrease from the previous year’s survey
- Providers: Only 25 percent of provider respondents had begun external testing and only a few others had completed this step. This is a decrease from approximately 35 percent of provider respondents that had begun external testing in the previous survey
There are a number of considerations as the deadline for ICD-10 looms. Here are a few key issues:
- Budget: Remediation of all systems to support the new standard is only one driver of cost and ideally should be thought of as an ongoing effort whenever possible. Remember that there will continue to be revisions to the ICD code set over time. Additionally, organizations should be prepared with cash reserves to minimize the impact of delayed payments due to all parties “coming up to speed” with the new standards
- Operations: Expect that training of all staff, not just providers and coders, will be an iterative process as constraints in workflow are identified with the new standard. Change management will be a critical challenge, not only in how coding between ICD-9 and ICD-10 will be handled electronically, but in all administration, including workflow, quality reporting, billing and payer contracting
- Independent Verification & Validation of Systems: Even with a thorough assessment, remediation and testing process, gaps in your preparation may still occur. Contingency plans and frameworks should be considered in advance of October. Even if your organization is prepared for the transition to ICD-10, there is reason for concern. If payers, vendors or other strategic business partners have gaps in their implementation, this could impact patient care, budget and general operations. Consider a process of testing data exchange with all partners outside of your organization to identify and address issues early
It is clear that a decision needs to be made so that all players can remove this uncertainty from their business. As of today, all signs point to a transition to ICD-10 in 2015 with many industry vendors and experts in support. There may be some sort of compromise to accommodate dual coding as a way to ease adoption, but that is still speculation.
Let’s see if it sticks this time, but be ready. Just in time for ICD-11?