ICD-10 Is Two Years Away; Will You Be Ready? (Part II)

Monday was t-minus two years to when all healthcare providers will be required to turn the switch from ICD-9 to ICD-10. And while 24 months may seem far in the future, it isn’t. For those who have yet to begin their ICD-10 migration project, what follows is a project plan outlining the steps you can expect to take between now and Oct. 1, 2014.

This timeline has been adapted from recommendations by HIMSS and American Health Information Management Association as well as others.

Yesterday’s article (which you can read here) covered the first steps:

Preliminary Phase (Now – October 31, 2012)

Phase 1: Assessment
Financial impact assessment (Nov. 1, 2012-March 31, 2013)
Staff/Partners, processes, and technology impact assessment (Nov. 1, 2012-May 31, 2013)
Training assessment (April 1, 2013-June-30, 2013)

This article covers the final steps, at a high level, you need to accomplish before  go-live and beyond. They are:

Phase 2: Design and Implementation
Business process changes (June 1, 2013-Dec. 31, 2013)
Internal Testing and Validation (June 1, 2013-March 31, 2014)
External testing and Validation (June 1, 2013-Sept. 30, 2014)

Go Live (Oct. 1, 2014)

Follow-up and Evaluation (Oct. 2, 2014 – ongoing)

By now you have identified the new technology, if any, you wish to implement, and the staff and workflows that will be changed to accommodate the impacts of ICD-10. Now comes the part where everything changes.

Business Process Changes

During this stage, remember the acronym MRICE, which stands for Management>Resources>Installation>Communication>Execution and represents the five steps, in order, you need to complete before you can move to testing and validation, and from there Go-Live.

Now that you’ve identified your budget, systems, people, and processes you need to complete this project, circle back with management in the form of your executive sponsor for validation to proceed. The executive sponsor’s role is to make certain you have the resources — money, time, and people — you will need to complete this project. Once in place, you can now proceed with installation of the systems, be it technology or workflow. Before you begin testing, you need to communicate with all the stakeholders about what they can expect, be it training, new workflows, operating interruptions, every possible impact. Only then, with management on board, resources in place, systems installed and stakeholders in the communications loop, should you move to execution.

Because ICD-10 is such a giant leap from ICD-9, include coder training as part of your execution. Inpatient coders will require up to 80 hours of training, which they should accomplish before beginning testing of the new systems.

HIMSS/AHIMA offers the following people, processes, and technology that will be put into play for this step:

People

• Project team (also called the steering or governance committee). Provide direction and coordinate all efforts in business/IT process changes in close collaboration with executive sponsors, revenue cycle/finance/HIM/IT/vendors/billers/coders/clinical education team for general staff & medical staff.

Processes Affected

• Change Management Team, Operations/Senior Management, Revenue Cycle/Finance, Admitting/Patient Scheduling, Clinical Staff, Medical Billers/Coders, Vendors/Contractors, HIM & IT staff, Patient/Outreach, Software Developers, General Staff.

Technology

• Software Upgrades/Changes. To enable ICD-10 compatibility including admissions/scheduling, EMR/EHR/coding software/DRG Grouper/payment management research/auditing/lab system/pharmacy system/clinical patient management system/report database/cancer reporting/CDC reporting;
• Information Technology. Upgrade/change to enable inter/intra-organizational interoperability, data mining for clinical and business intelligence.

Internal Testing & Validation
Now that you’ve built it (or at least a sandbox version of your new systems and workflows), will it work? The only way to find out is through testing. Using the new workflows identified during Phase 1, you will create test scripts that will be tested by employing staff members that will be using them. While HIMSS/AHIMA recommends that “everyone involved in the business should be part of the testing,” that is an expensive and productivity-losing proposition. You may instead select power users in each department to handle the system testing.

External Testing & Validation
Simultaneously with internal testing and validation you should be testing with those outside your direct control, especially your outsource partners, at least as far as you can. There is an ulterior purpose with external testing beyond just knowing if you can send and receive data. This is how you will uncover if your partners are as ready for ICD-10 as you are.

Despite how prepared your organization is for ICD-10, your partners will make all your hard work amount to nothing. This test phase is where you should learn whether the contingencies you built in the financial impact assessment phase will be required.

For both internal and external testing and validation, HIMSS/AHIMA says you should accomplish the following:

This phase allows organizations to test all processes and all areas that send and/or receive information from outside the organization (e.g. a provider sends a claim to a health plan). Test data is exchanged to assure that proper information is sent, correctly received and processed by the receiving organization. Each individual step in a process is tested to ensure accurate and proper function. A complete “end to end” test – from the beginning of a patient experience through claims payment and reporting should be conducted for the most frequent and most important types of services.

Go Live
Medicare and Medicaid expect you to go-live on Oct. 1, 2014. But some organizations will do so long before then and will be dual-coding in both ICD-9 and ICD-10 for several weeks before the required changeover. The cost of doing that is not incidental.

Follow-up and Evaluation
After go-live is when the real work begins. As HIMSS/AHIMA pessimistically puts it, “There will be significant post-implementation issues, such as claims denials and rejections or coding backlogs.” Make certain you have the resources in place to manage these issues. HIMSS/AHIMA recommends establishing a “Post ICD-10 Committee” for this purpose, as well as serve as the group that will evaluate the project overall.

Committees are great for planning and consensus building, but when there are issues, there really should be a one person with whom the buck stops. While the committee can certainly “review implementation results, evaluate success against established criteria, and … identify what works and doesn’t work,” as recommended by HIMSS/AHIMA, there should be a single individual who should be responsible for correcting issues.

HIMSS/AHIMA identifies the following people, processes, and technology that are affected post-go-live:

People

• Providers, Coders, HIM, IT, Finance, Patient Financial Services.

Processes

• Coders. Productivity will be impacted significantly with more codes and higher complexity in identifying codes from clinical documentation.
• Providers. Will be required to answer more questions from coders for more specific documentation requirements.
• Revenue Cycle. Will need to analyze reimbursement to ensure payment and that organizations are paid accurately as anticipated.
• Finance. Focus on cash and increased cost due to unforeseen circumstances in delayed revenue, decrease in productivity and technology hiccups.

Technology

• Vendor evaluation. Although vendors claim readiness, there will be post go-live adjustments required. Do the products perform (some legacy systems maybe strained with the number of codes / logic)? Do products still provide value (logic /lookups /displays of data may not be useable with the number of codes & length of descriptions)? Did vendors communicate well during the process or were they not “transparent?” How are the workflow tools working? What about payers that did not transition? What is the plan for conversion and how will information be communicated and contracts negotiated once 2 years of claims history is available? Vendors are also subject to limited resources and will be hard pressed to be proactive in the Post Go-Live phase.