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| ICD10 Watch by Tom Sullivan |
AAPC's 16 steps that ease ICD-10 implementation
Posted on Wed, Aug 11, 2010 - 07:58 amAs part of a broad campaign titled “ICD-10 Changes Everything,” the American Academy of Professional Coders (AAPC) has sketched a road map providers can use to reach ICD-10 compliance and do so by the government-mandated deadline.
“It doesn’t have to be completely overwhelming if they just take a systematic approach, do it in steps, follow a timeline, and work with their vendors,” says Rhonda Buckholtz, vice president of business and member development at AAPC. “And if physicians start now, they’ll be able to make that transition with quite a bit less frustration – and probably a lot cheaper – than if they wait until further down the road or until the last minute.”
[Related: Part 3: Understated aspects of ICD-10 for coders. Podcast: On coder shortages and other ICD-10 challenges.]
And so here are the 16 steps that AAPC says everyone needs to follow for a successful ICD-10 implementation.
1 Organize the implementation effort
2 Develop an ICD-10 communications plan
3 Conduct impact analysis
4 Organize cross0functional efforts
5 Budget development
6 Internal system design and development
7 Develop training plan
8 Contact system vendors
9 Implementation planning
10 Phase 1 training
11 Business process analysis
12 Phase 2 – Education and planning
13 Policy change development
14 Outcomes measurement
15 Deployment of code by vendors to customers
16 Implementation compliance
“If providers follow these steps and take a look at what goes into them, it will flow much quicker for them, be much less disruptive, and will hopefully continue to get them paid after October 1, 2013,” Buckholtz explained.
In addition to the 16 steps, the AAPC offers a number of ICD-10 compliance tools, including a timeline, benchmark tracker, and a floor plan that diagrams changes of which every physician office should be keenly aware.
Reader poll: Which ICD-10 related cost is of most concern to you? Come by ICD10Watch to vote, please!
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Comments
The "Billion Dollar Biller"
The "Billion Dollar Biller" plus CMS, AAPC and AHIMA all say it's way too early for ICD-10-CM training.
My name is Jim Davis and I'm the founder and President of PMIC. Unlike most people who publish coding books, I've done what you do. I have billed over $1 billion dollars in health insurance claims for physicians and other health care providers. That's why some people call me the "Billion Dollar Biller".
In my opinion, training on a coding system you won't be using for over three years (39 months) doesn't make sense. Think about it. Do you really need to spend your valuable time and money learning something that has no immediate practical use?
Do you remember Y2K, when the world was supposed to end because computer systems would not be able to handle the date change from 1999 to 2000? Regrettably, health care organizations spent millions developing disaster plans for something that never happened. The same confusion and scare tactics are being used to sell you ICD-10-CM products, newsletters, seminars and training programs that you don't yet need.
You already know that ICD-10-CM is different than ICD-9-CM. You know that it has more codes, has a letter in the first position, and may be 3-7 digits. Depending on what extensions you include, ICD-10-CM has 5-10 times as many codes as ICD-9-CM. But that doesn't mean it's harder to learn or to use, just that there are more choices. A professional coder will quickly get the look and feel of it. At this time, that's really all you need to know.
In you're skeptical, please read the March 24, 2010 blog by Tom Sullivan at www.icd10watch.com, titled "CMS, AAPC, AHIMA all agree it's too early to start ICD-10 training." The blog states "All three, in fact, recommend that healthcare organizations should start training during the year of implementation, which means the first quarter of 2013, or perhaps 2012’s final quarter." According to the AAPC and AHIMA experts quoted in the blog, "training coders, particularly those already proficient in ICD-9-CM, will require a mere matter of days." Yet every day you receive mail and email offering you ICD-10-CM books, planning and training...including from the organizations above who said it's too early.
You have a choice. You can invest now in ICD-10 training that you don't need, will forget, and will have to repeat later, or you can save your money and wait to start your training until late 2012 or early 2013, closer to the implementation date.
James B. Davis, President
Practice Management Information Corporation (PMIC)
http://pmiconline.com
Mr. Davis, I read a lot of
Mr. Davis,
I read a lot of material every day and come to this site frequently for information to either learn from or share with my clients whom are both health plans and providers. I disagree with your opinion that training won't be necessary until early 2013 for several reasons:
- There is an immediate practical use for payers who have to remediate hundreds of systems in order to begin testing in 2012. To do the remediation, these analysts need to know how to convert from ICD-9 to ICD-10 and that should happen as soon as possible.
- So, at a minimum, the staff doing the analyses and software changes in benefits, contracts, medical policy and reporting should begin training now, not later...
- Also, if training is done sooner, health plans are allowed time to re-think how they manage benefits and how they reimburse by diagnosis codes and perhaps will change how they manage them if given time to consider these changes. Waiting until just before the compliance date may burden the operations un-necessarily and may cause delays in payment, etc.
It may be too early for providers to begin training, but if providers and plans don't begin close communications on how claims will be submitted, both can suffer impacts to their operations and revenue management. Awareness training should be done so that they are informed of the upcoming challenges and will be able to plan more effectively.
With a coding background myself, I find that coding in ICD-10 is so much easier - the challenge will be for providers to ensure clinical documentation supports the level of specificity for the code they bill to the plans. That training can't start too early.
Thanks for the opportunity to state my 'two cents worth'.
Faye Newsome
Healthcare Practice Director
TEKsystems, Inc.
Thanks for your comments.
Thanks for your comments. This was not just my opinion, but the opinion of CMS, AHIMA and the AAPC as recently as March a year ago.
What I see every day is these same organizations using scare tactics to get people to purchase seminars and training programs...exactly like Y2K.
I have no issues with "planning" for ICD-10, but as you stated "With a coding background myself, I find that coding in ICD-10 is so much easier." According to AHIMA and the AAPC, professional coders will develop proficiency in ICD-10 coding within 3 days to 40 hours.
Training coders now, when they can't apply the knowledge for (at least) 30 MONTHS, makes absolutely no sense from a professional training perspective.
My two cents.
Jim Davis, President
PMIC
http://pmiconline.com
Mr. James B Davis We
Mr. James B Davis
We appreciate the comments made, but you may only be looking at this from a coder’s perspective. Yes, we agree that now is too early to learn the full code set, as we stated in the March 24th article you cited. (We don’t even offer comprehensive code-set training yet.)
There is, however, so much more to ICD-10 than simply learning the codes. ICD-10 will change everything in today’s physicians practice. While coders may be able to wait to learn the codes, a practice manager waiting until 2012 to begin the implementation process could be making a major mistake that could seriously impact revenue. Every part of the practice will be impacted—documentation, policies, contracts, software, forms, superbills, and more.
The sixteen steps shared above are based on the full implementation of ICD-10 within the practice, of which coding should be one of the last steps (mentioned as step 15 on the list above). We do not feel that full implementation can be successfully achieved if it is begun the last quarter of 2012. We believe that being prepared for this change will ensure practices will remain profitable and ultimately continue to be successful.
Deborah Grider, CPC, CPC-H, CPC-I, CPC-P, CPMA, CEMC, COBGC, CPCD, CCS-P
President & CEO
AAPC
Ms. Grider: Thanks for your
Ms. Grider:
Thanks for your comments.
I assure you that I'm looking at this from every perspective. I have written/edited over 200 books on coding, billing, practice management, and have given hundreds of seminars on data processing to health care professionals. In addition I am an experienced systems analyst and IT manager and have written over a million lines of code for computer systems. Plus, I was a former executive at Cedars-Sinai Medical Center and have worked in virtually all segments of the health care industry.
I clearly understand that it's "more than learning the codes." However, most of the work will be done by third parties, i.e. the software vendors, forms manufacturers, code book and data file publishers, etc.
During the Y2K frenzy, I received hundreds of documents from hospital committees requiring that I verify that my products, which contain no dates, would be Y2K compliant. Hospitals wasted thousands of hours and millions of dollars planning for a crisis that did not happen. It took me exactly 30 minutes to write a simple century handling routine for my own computer systems.
I don't disagree with the sixteen steps, only with the need to rush into this. While October 2013 appears to be a firm date, there is already a growing provider based movement to delay it. In addition, the likely reversal of Obamacare, and a new focus on real ways to reduce health care costs, may also impact the conversion to ICD-10.
With the current economic recession, we believe that there are more important issues for providers, payers, and facilities to spend time and money on than ICD-10.
James B. Davis, President
Practice Management Information Corporation (PMIC)
Mr. Davis, I've got a
Mr. Davis,
I've got a burning question for you!
First, though, thanks for your comments. Since I wrote the above story I'll weigh-in here by reiterating that the 16 steps concern what might be considered a full deployment cycle and are NOT just about training at all. You were right in pointing out that it's a bit early for in-depth training -- though it may not be too soon to start planning for such training as AHIMA has explained to me that just fitting all the puzzle pieces together to form a training picture will likely consume more time than folks expect.
And with industry bodies and consultancies projecting that ICD-10 conversions will take anywhere from 2.5 to 4 years, I stand firm that now is in fact the time to get started, if one has not already, with the overall project.
That said, onto my questions. You wrote within your second comment that "there is already a growing provider based movement to delay ICD-10" and that "the likely reversal of Obamacare, and a new focus on real ways to reduce health care costs, may also impact the conversion to ICD-10."
If you don't already know where I'm going with this well, then, here it comes: Please explain the likely reversal of Obamacare and how that might occur in time to delay ICD-10. While not impossible, that seems to me like a stretch.
Naturally, I'd love to read more about the provider based movement to delay ICD-10. I don't doubt that many, if not the overwhelming majority, would rejoice were the deadline pushed back, but do you have evidence pointing to some sort of organized movement?
I'll close by asking that you not take my questions as attacks but, rather, the curiosity of a reporter always on the prowl for ICD-10 stories.
Thanks,
Tom
Tom Sullivan
Community Editor
ICD10Watch
(914) 282-8762
http://www.icd10watch.com/
www.twitter.com/icd10watch
Tom, Thanks for your
Tom,
Thanks for your comments. I welcome your questions and do not consider them attacks. While it is not my title, I consider myself a "reporter" too as part of my job is to keep the 100,000+ physicians, hospitals and third party payers we serve informed about issues that affect them.
With regard to organized opposition, I refer you to testimony regarding implementation of the HITECH Act before the House Energy and Commerce Subcommittee on Health presented by
Roland A. Goertz, MD, MBA, FAAFP, President Elect of the 94,000+ member AAFP on July 27, 2010 (http://energycommerce.house.gov/documents/20100727/Goertz.Testimony.07.2...). On page 5 of his testimony Dr. Goertz stated "In addition, practices are at their maximum capacities for change, and we ask that your committee not make additional requests of these physicians during this transition and even look at the required adoption of ICD-10 as something to delay." And yes, I was aware of this planned testimony when I wrote my comments on August 25th.
As you know, the majority of citizens in the United States are in opposition to Obamacare. The November elections are set to return control of the House, and maybe even the Senate to the Republicans. This will likely result in attempts to reverse Obamacare legislatively via policy changes and funding restrictions. The March 2004 Rand Corporation report on the cost benefit of converting from ICD-9-CM to ICD-10 stated "Thus, our best guess is that the cost of conversion will run $425 million to $1,150 million in one-time costs plus somewhere between $5 million and $40 million a year in lost productivity." The MGMA reported in October 2008 (http://www.mgma.com/press/article.aspx?id=22612) "New Study Finds ICD-10 Mandate Hardship for Health Care Providers" a study that quantified costs by size of practice and stated that CMS had underestimated the cost.
If I were on a Congressional panel looking for ways to a) reduce health care costs for providers and payers, and b) reduce government control over the health care industry, I would find the opportunity to save $500 million to over $1 billion immediately by permanently or temporarily delaying the implementation of ICD-10 very tempting.
I hope this answers your burning question(s). If not, let's continue the discussion.
Jim Davis, President
Practice Management Information Corporation
Mr. Davis, Thanks for
Mr. Davis,
Thanks for writing back.
You and I could battle back and forth on what constitutes an organized movement, what will happen in the November elections and beyond, and what each of us might do in the hypothetical event that we were serving on a congressional panel weighing whether or not to postpone ICD-10 – and, you know, that might be even fun, if only for us, because I stand in opposition to the points you expressed.
Rather, I'll try to advance this conversation with another question that might help ICD10Watch readers: Do you advise the “100,000+ physicians, hospitals and third party payers” you serve (which I take to be the folks who buy your books, no?) to actually ignore CMS and the non-government entities who recommend that health org's start right away and instead suggest that your customers bank on either the November elections or some sort of provider movement to delay ICD-10 so firmly as to not even bother starting the gigantic conversion yet? And please explain either way because I just don't see the concrete reasons for delay with all that's at stake.
Perhaps this is a matter of opposing viewpoints, since I think that when it comes to business decisions betting on somewhat abstract possibilities is a chancy game. What with basically every industry body, analyst firm, consultancy, and CMS itself telling providers, payers, and clearinghouses that the clock is ticking and they'd better get going, yours would certainly be an aggressively contrarian opinion – which is not at all to say an unwelcome one here at ICD10Watch.
Now, I understand your point that health org's have considerable undertakings ahead of them but, I believe, your argument that those other tasks (healthcare reform, Meaningful Use, et. al.) should take precedence over ICD-10 twists quite easily into the obvious counterpoint that the more projects healthcare IT shops have, the wiser they'd be to get ICD-10 and those others underway as soon as possible.
Again, I look forward to your response. If you have solid reasons that exist today for holding off on ICD-10, then I'm certain our readers would like to know plenty more about them!
Thanks much,
Tom
The November elections speak
The November elections speak for themselves. Due to the GOP takeover of the house (with the Senate and Presidency to fall as well in 2012) Obamacare is headed for repeal, defunding, and/or being ruled unconstitutional (or all three).
My opinion regarding ICD-10 training is the same opinion held by CMS, AHIMA and the AAPC in March 2010 (as reported in this blog). A year later, still (at least) 30 MONTHS away from implementation of ICD-10, my opinion is that it is still too early to introduce coder training.
I have no issues with conversion planning by hospitals, payers, clinics, etc. My issue is coders being frightened into paying for seminars or training that they will not be able to use for (at least) 30 months by the same organizations who said that coder training should start in late 2012 or early 2013 (until they found there was money to be made in the meantime.)
We have always taken the high road on issues such as this one. We don't sell our customers products just because we can, but rather because they really need them. Maybe a bad business model, but it has served us well for the past 25 years.
James B. Davis, President
Practice Management Information Corporation (PMIC)