By Kathleen Rowland, CPC, CPC-I, CEMC

The planning must begin!! The final rule from the Centers for Medicare & Medicaid Services (CMS) has set the ICD-10 implementation date as October 1, 2014. Implementation is much more than simply purchasing new code books and learning new code sets. Many areas of your practice and operations will be affected. This is the biggest change to hit health care thus far. The recent one year delay allowed extra time for the necessary preparations but this additional time should not be wasted.

Minimize Financial Impact Where You Can
Strategic planning and anticipation of productivity issues can help a practice minimize the implementation impact. Begin by organizing the transition effort and develop an ICD-10 steering committee that will help identify all areas of impact for the practice. This may be a committee of one or two staff members in smaller practices or a cross section of billers, coders, IT, managers, physicians, administrators, etc. in larger practices. It is important to get representation for each area of the practice to be sure every area of impact is identified and explored.

Involve physicians early on so that they understand the importance of preparation as the migration to ICD-10 occurs. The team should meet initially to begin to identify the elements necessary for a smooth transition and present those plans to management. This planning should include identifying how communication will be handled throughout the implementation process, training needs and education plans, and coordination with vendors, business partners, and other providers.

Talk With Your Vendors

Create a list of all your practice's electronic systems and work flow processes that use ICD-9 codes today, both clinical and administrative. Include payers, contractors, clearing houses, and vendors. Find out how much each of these groups will be affected by ICD-10 and how ready they are for it, including what their implementation plans are. Define requirements you will need from vendors to support your ICD-10 implementation (will vary by vendor). Can the database support both the ICD-9 and ICD-10 code sets for a period of time? Can IT distinguish between an ICD-9 and an ICD-10 code? How will the code set updates be managed? Determine if systems vendors and/or clearinghouses/billing services will support changes to systems, supply a timeline and cost estimate for implementation changes, and identify when testing will occur. Determine anticipated testing time and schedule. When will they start and how long will they need? What will be required for testing? Put everything in writing!

Begin testing 4-6 months before the deadline of October 1, 2014 to assess glitches that may affect payment. Identify crosswalk capabilities with your system in operating in ICD-9 and ICD-10. Workers compensation carriers are not considered covered entities under HIPAA and therefore are not required to make the transition to ICD-10. If you are contracted with these carriers, contact them and ask them if they will be converting to the ICD-10 system.

Explore "Plan B" options in case your vendor does not progress fast enough, including operational work-arounds and vendor replacement alternatives.

Prepare for Training 

Second only to system upgrades, training will be the biggest expense for the practice. Develop a separate educate plan specifically for ICD-10. Do the training in phases, beginning with the background and history, rationale for change, and final rule highlights, then continue through guidelines and code set training. Measure the retention of what you are learning by conducting post-training testing. Evaluate varying levels of training-coders will need in-depth code set training and receptionists will need less preparation. Evaluate what options are available to train staff (onsite, vendor training, community courses, webinars, certification courses, etc.) as well as format choices (classroom training, web-based training, or self-guided materials). Develop a budget once your methods are determined.

One of the largest impact areas will be the clinical documentation. Auditors and coders struggle with this issue even now; documentation has potential to become more of an issue with ICD-10, which is data driven. If only unspecified codes are used in ICD-10, we are no further in capturing the specific clinical "picture" of the patient. There also may be a future possibility of payers not reimbursing for unspecified codes when the documentation supported a more specific code.

The best way to confront this issue is through monitoring and education. If you are not already performing documentation audits, begin now. Incorporate an ICD-10 readiness section of your audits, or do a separate ICD-10 readiness review as a benchmark. Run a frequency report of the top diagnosis codes currently being utilized by the practice. Pull a sample of documentation for each provider that would represent these "top codes."

Have the auditor assess the documentation and determine:

• Does the documentation support the current diagnosis reported?
• Will the documentation support an ICD-10 code?

The auditor must be familiar with the ICD-10 guidelines and codes to make this determination. Once the audit has been conducted and analyzed, the practice will have a good assessment of documentation deficiencies and can develop a priority list of diagnoses requiring more detail. The audit will also identify those providers who would benefit from a focused ICD-10 training.

To ensure improvement, implement a documentation improvement program within the practice and monitor the documentation on an ongoing basis. Identify areas where providers are deficient and who needs more assistance and training. These audits should be conducted periodically to validate ICD-10 compliance. As with any audit, submit a report to senior management and the provider.

If you do not have a trained certified professional coder (CPC) on staff that would be comfortable performing these audits, contact AAPC Physician Services to schedule an ICD-10 Readiness Assessment. Do not skip this step! This is a critical element as you begin the preparation and implementation process.

Achieving ICD-10 compliance is essential for the success of the practice. Working together towards a successful transition to ICD-10 will be vital to transforming our nation's health care system and essential to maintaining the vitality of the practice.

Kathy Rowland has over 25 years of experience in the areas of health care administration and management. Nine years were spent specifically in the development and implementation of practice-based compliance plans, auditing documentation, and litigation support. She is currently on AAPC's ICD-10 Curriculum Training Team.