CMS offers practical tips for ICD-10 implementation
The Centers for Medicare & Medicaid Services (CMS) released two tip sheets this week.
They only seem to be in e-mail alerts from CMS so I'm going to post the content here. The first is some basic information on how healthcare providers can prepare to improve clinical documentation:
- Inventory Systems and Identify Discrepancies: You should review your systems that currently use ICD-9 in order to identify areas in your revenue cycle, reimbursement rates, health information management, electronic medical records, and clinical systems that will eventually use ICD-10. These systems will be affected by the increased specificity of documentation as well as the increase in number of codes used in ICD-10. Your systems inventory will need to evaluate any potential gaps in clinical conditions or work flow processes that could be affected by increased documentation. Once you have identified any discrepancies, you can update and modify your systems and processes prior to transitioning to the new code sets. This will save your organization time by finding incomplete or non-specific data and ensuring that they do not cause a delay with coding and billing when you finalize implementing ICD-10.
- Evaluate Current Software Systems: As you conduct your systems inventory, you may realize that some of your systems have become out-of-date or are redundant. You will need to determine if it is more cost-effective and efficient to upgrade these systems or centralize and replace them before ICD-10 implementation.
- Train and Educate Staff: Your organization should identify staff members, from providers to coders, who currently use ICD-9 codes. Staff who will now be using ICD-10 will need training to become familiar with the increased documentation standards necessary with the new code sets. Training will help staff members become comfortable with both the heightened specificity and increased number of code sets that they will be using frequently.
- Test the Documentation Process: Finally, your organization will need to test each stage of the new documentation process in a trial setting. Staff members should simulate a typical patient encounter in its entirety to ensure that data is being documented thoroughly and consistently. This will also help identify any areas that still require improvement in the coding process.
The second is a broad checklist of what needs to happen during an ICD-10 transition:
- Educate staff and leadership about ICD-10
- Appoint an ICD-10 coordination manager and delegate a steering committee to manage the transition
- Train staff on changes in documentation requirements from health plans and how this will affect work flow
- Perform an impact assessment
- Examine existing uses of ICD-9 codes in order determine aspects of work flow and business practices that ICD-10 will potentially change. Be sure to evaluate planned and ongoing projects as well
- Create a list of staff members who need ICD-10 resources and training, such as billing and coding staff, clinicians, management, and IT staff
- Plan a realistic and comprehensive budget
- Estimate a budget that includes costs such as software, hardware, staff training, and any initial change in patient volume
- Coordinate with external partners
- Contact system vendors, clearinghouses, and billing services to assess their readiness and evaluate current contracts
- Ask your vendors how they will support you in the transition to ICD-10 and request a timeline and cost estimate
- Analyze existing health plan trading partner agreements
- Get ready for testing
- Request a testing plan to schedule from your vendor
- Conduct internal testing within your clinical practice as well external testing with payers and other external business partners after you have completed the planning stages
These are broad tips but still useful. It's also worth reminding that CMS has ICD-10 implementation guides for:
Patrice Morin-Spatz lists nine ways that ICD-10 implementation could hurt healthcare providers and patients:
- "Updating legacy computer systems."
- "New certification criteria."
- "Reformatted billing."
- "Dual-entry procedures during transition period."
- "Loss of productivity."
- "Inaccurate diagnoses resulting from test ordering."
- "Increased specificity could lead to increased reliance on erroneous data."
- "Denial of benefits resulting from inaccurate coding."
- "Diagnosis codes must match treatment codes to guarantee insurance coverage"
These problems say more about the limitations of our healthcare system than the limitations of ICD-10 coding. Healthcare providers will wrestle with these problems even if they leapfrog into ICD-11 implementation. (Healthcare Finance News)
Maybe all we really need is for the CMS to set an ICD-10 compliance deadline and really mean it. (Informationweek)
This is a pretty good post that addresses how to choose the right technology "partner." One of the recommendations is that you find a vendor that is innovative. Which means look at how they approach:
- Leveraging the ICD-10 codes
- Minimizing fraud
- Capitalizing on enhanced accuracy of billing
- Effecting quicker payment resolutions & reimbursements
For the most part this is a "In case you haven't heard about ICD-10" kind of post. But there is this interesting explanation of how implementation will affect radiologists:
"They will have to improve their documentation. The beauty of radiology is they have been electronic for a long time, so all the systems issues [that must be upgraded for ICD-10] don’t impact them as much. There are many things that will have to be documented for I-10 that don’t have to be documented for I-9. Even if someone is a great documenter today, there will still be things they will have to change about their documentation for I-10. Injuries for a radiologist will be the biggest challenge; fractures are a really good example."
It's not the tech that's going to be a problem. It's changing work process to improve documentation. (Diagnostic Imaging)
Again, pretty much standard stuff. But there is this very specific information on maintaining Certified Professional Coders (CPC) certification:
"There will be a proficiency test conducted by AAPC that all CPC’s will be required to take in order to maintain their credentials. The timed, online proficiency exam will consist of 75 questions strictly related to ICD-10-CM. Assuming that October 1, 2014 is the implementation date, the test will be available October 1, 2013 through October 1, 2015. The test must be passed by October 1, 2015 to maintain CPC credentials."
CMS released six files:
- 2013 Code Descriptions in Tabular Order - Updated 12/5/11 [ZIP, 1MB]
- 2013 Code Tables and Index [ZIP, 17MB]
- 2013 Addenda [ZIP, 353KB]
- 2013 ICD-10-CM Duplicate Code Numbers [ZIP, 64KB]
- 2013 General Equivalence Mappings - Diagnosis Codes and Guide [ZIP, 583KB]
- 2013 Reimbursement Mappings - Diagnosis Codes and Guide [ZIP, 266KB]
There are five things your impact assessment needs to include:
- "Documentation Changes"
- "Reimbursement Structures"
- "Systems and Vendor Contracts"
- "Business Practices"
In an online survey that asked "Would you be prepared to skip ICD-10 and go straight to ICD-11?":
- 52 percent said No
- 48 percent said Yes
That's with 189 respondents. What would be really interesting is an explanation of why they think they're prepared to leapfrog into ICD-11 implementation. (Healthcare IT News)
AICPA Health Care Expert Panel develops TPA on accounting for costs incurred during ICD-10 implementation
The American Institute of Certified Public Accountants has new standards for accounting for the cost of ICD-10 implementation. Unfortunately the info is available to only members. Hopefully your accountant is up to speed. (4A's SmartBrief)