ICD-10: Six Months Later, and We Still Have Questions

It's been nearly six months since the Department of Health and Human Services proposed a delay to the ICD-10 implementation deadline, and the industry is still waiting to hear a final ruling. At this point, even pushing back the ICD-10 compliance date by a full year to October 1, 2014, means that you have just over two years to get your practice ready. And, if the original deadline of October 1, 2013 is upheld, there is only one year left to prepare. We cannot say it enough: Holding off on your preparations while we wait to hear the final rule on the deadline will put your organization in jeopardy.

Recently we held a webinar in partnership with PNC Bank about establishing a line of credit to avoid cash flow problems during the ICD-10 transition. Managing delays in payment during the transition is a major concern for many physicians, so we recommend that practices build a line of credit at least six months in advance of the ICD-10 deadline.

During the webinar, we heard several other concerns related to the ICD-10 implementation. Here is a rundown of some of the top questions we received, along with answers that should help your own practice with your transition plans:

1. How do I start planning our transition?
Planning your practice's entire transition to ICD-10 can be overwhelming  that is likely why many practices are hesitant to begin. It may be helpful to identify all the areas in which ICD-10 codes touch your business, so that you can address each area in your plan. Our ICD-10 Implementation Planning Worksheet may be helpful as you think through your transition timeline.

2. What should I do if my staff isn't making the upcoming transition a priority?
Since we still do not have a firm deadline for ICD-10, it has been easy for people to brush the implementation aside. But the fact is that ICD-10 will impact your practice. In Canada, practices experienced up to a 50 percent decrease in productivity during the first six months of ICD-10. Loss in productivity means that you will process fewer patients and collect fewer payments, which is going to impact your bottom line. Speaking in terms of how staff time and revenue will be affected may help convince non-believers to make ICD-10 a priority.

3. Will we have a testing period for ICD-10, and when will it occur?
Yes, there will be a testing period among payers, clearinghouses, providers, and vendors, though we will not know when testing will occur until a decision has been made regarding the delay. Initially, the industry hoped to run thorough end-to-end testing that would monitor claims from the time they are entered all the way through the reimbursement. However, testing of this magnitude will be very time-consuming, and payers would need to provide mock adjudication systems. There may not be sufficient time to develop and test a plan of this degree.

Practices also should do their own internal testing to ensure their systems are ready for ICD-10.  The American Medical Association recommends that practices spend two to three months running internal tests to verify that your practice management system can handle ICD-10 codes and that your reports are formatting properly. You also should allow for six to nine months of external testing with your clearinghouse, vendors, and payers.

4. I've heard some payers will not transition to ICD-10. Does this mean I need to submit my claims in both ICD-9 and ICD-10 formats?
All health care payers, providers, and clearinghouses are considered covered entities under HIPAA and must comply with the ICD-10 mandate. However, workman's compensation and property and casualty payers are not covered entities and are exempt from ICD-10.

Just as with 5010, it is possible that not all payers will be ready for ICD-10 on the mandated implementation date. The delay in enforcement for 5010 is an example of how industry as a whole was not ready for a mandated change. In order to continue to submit claims to all health care payers, it will be important that you are able to submit in both ICD-9 and ICD-10 formats.

5. Will we experience delays in payment from some payers?
There is a real possibility that you will experience delays in payments and claims processing with the implementation of ICD-10. The industry is doing its best to prepare, but there are bound to be bumps in the road with a change as massive as the ICD-10 code set. To prepare for reimbursement delays, establish a line of credit to tide the office over during the first months following implementation of ICD-10. This line of credit will allow you to keep your office functioning even if your cash flow slows.

6. How will my vendors' transition plans affect me?

We recommend contacting your vendors to find out what changes they are making to support ICD-10. You may want to ask:

Tell us, what concerns does your practice still have about ICD-10?

Shelly Guffey is the manager of premier accounts and vendor partners for Gateway EDI. Dawn Duchek is the industry initiatives coordinator for Gateway EDI. For a compilation of helpful industry resources on ICD-10, visithttp://www.gatewayedi.com/icd10/.