Many hospitals and health systems have been gearing up for the transition from the ICD-9 to ICD-10 code set by focusing on clinical documentation improvement programs and implementing extensive training and education for clinicians and coders. On March 31, however, Congress passed the Protecting Access to Medicare Act of 2014. While the bill prevented a 24 percent cut in Medicare physician pay, it also included a seven-line provision to delay the conversion to ICD-10 by at least one year. In light of this delay, healthcare leaders should consider a fresh look at plans, timelines, and critical decision-making, evaluating their current state of readiness against other organizational initiatives.
Here, Chris Armstrong, principal and ICD-10 practice leader for Deloitte Consulting LLP, and Steve Burrill, partner and health care provider advisory practice leader for Deloitte & Touche LLP, offer strategies to consider for determining the best path forward during the delay.
What are some key concerns healthcare organizations should consider at this point in the transition?
Chris Armstrong: Many organizational leaders are evaluating the work they’ve completed and determining how time, efforts, and costs can be optimized with the delay. A key concern will likely continue to be ensuring that all systems are go. Everything needs to be working properly, so that claims can be submitted accurately and payment reflects the level of services completed. Using this as the anchor for decision-making, leaders might need to re-forecast their current spend, resource alloca¬tion, ability to maintain testing activities without dupli¬cative efforts, and potential costs of continued momentum. Decisions related to education and training program timelines also need to be reviewed, as stakeholders may not be willing to engage as initially planned or training programs may need to be repeated closer to the new implementation date.
Steve Burrill: It’s also important to recognize that even with the delay, the transition probably won’t go as smoothly as expected, and payment is likely to be affected. Leaders should consider adopting a “Let’s turn the delay into an opportunity” mind-set and evaluate what can be accomplished now that the original deadline has been changed. These elements can be brought into revised remediation plans.
Prior to the delay, HFMA had seen many organizations focused on present and near-term activities while not fully developing contingency plans if their own readiness or that of payers fell short. What advice would you offer now in light of the delay?
Armstrong: Many organizations had started to collabo¬rate with payers, clearinghouses, and third-party entities by testing claims through the end-to-end process. Many providers are contemplating how they can capitalize on this delay and engage in enhanced testing to enable true transaction evaluation while also conducting deeper analytics. Reaching out to third-party entities to confirm willingness to continue testing and expanding participa¬tion may be beneficial to organizations who continue their momentum.
For providers deep in implementation, ICD-10 has shown to be more complex than originally expected, and the extended timeline could allow for more thorough testing of processes and technologies. The previous timeline had many using a hurried, risk-based approach that was focused only on the most critical areas.
What else is necessary?
Burrill: Providers that maintain momentum could be able to achieve goals they previously set but then altered due to time constraints, such as the ability to thoroughly practice ICD-10 coding, produce usable test data, or conduct dual coding for a full nine months to a year prior to implementation. Also, the art to being ready is having both the people and tools in place to analyze the results. Many organizations have yet to take the time to not only identify the resources for this analysis but also deter¬mine whether performance will align with expectations.
Armstrong: As a part of remediation activities, we were helping clients establish baseline metrics to compare performance pre- and post-go-live and monitor trends, just as you would with a system implementation. These metrics can be put in a dashboard-type tool so that vari¬ances can be easily identified. Organizations not currently using such metrics in an easy-to-track tool can use the additional time as an opportunity to start critical metric monitoring. Additionally, organizations should consider whether they need to assess vendor contracts and retention/ incentive programs to determine extension provisions and updates to accommodate the extended timeline.
How can organizations leverage what they have already accomplished?
Burrill: We’re already starting to see clients revise timelines to refocus training programs on documenta¬tion improvement, regardless of the code set. Accurate documentation has always been important but has never been an easy task for physicians and other clinicians. There are advantages organizations can gain in taking the results of native coding outcomes and early training findings and incorporating them into a more advanced clinical documentation program.
Armstrong: The timeline extension may enable organizations to better advance their efforts in blending Meaningful Use with ICD-10 clinical documentation. Taking this extra time to link documentation requirements to order sets, smart templates, and documentation tools could give organizations a way to leverage existing training materials and retain knowledge. Additionally, the extension may allow more time for providers to actually realize benefits of CAC (computer-assisted coding)—a technology that was perhaps not an option with the original deadline.
What are some considerations that organizations were not yet focusing on, but they should now?
Armstrong: Many organizations have spent a lot of time in the planning process and haven’t thought about: “Once I go live, I don’t want to eliminate the resources I just garnered.” It’s important to consider how to best use these resources both with the delay and after the new ICD-10 compliance date. When the delay occurred, many organizations were just beginning to consider an organizational “go live” command center focused on system issues, denials, coding questions, and underpay¬ment analysis. It could be beneficial, for example, to have team members who can provide just-in-time education when coders are struggling with code selection or docu¬mentation issues. Additionally, the results of early adop-tion indicated that expanding ICD-10 practice time can dramatically impact productivity and code accuracy and minimize payment variances. Taking the time to deep dive into the more detailed data reporting and analytics could give organizations a chance to garner expertise they may not have had as of the previous deadline.
Burrill: All in all, it isn’t likely that this is a gloom-and¬doom scenario. In many respects, it’s the beginning of the next phase. We’ve all worked very hard to get to this point. The healthcare industry now needs to understand the value that can be captured. The industry could be much better served with all of this new information. We’re likely to have a better understanding of how to deliver better care, even though we could have some challenges that go along with having something that is more robust and stronger. We might also look back at this five years from now and say: “Yes, it was lot of hard work, but we got through it, and look at the better system we have today.”
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Publication Date: Thursday, May 01, 2014