The Time is Now – Ten Steps Organizations can Take to Successfully Comply with ICD-10

On October 1, 2013, the U.S. will join many countries in the international community by mandating the switchover in code sets for healthcare diagnoses and procedures from ICD-9 to ICD-10. These code sets are used to report and code diseases, injuries, impairments, and other health problems, in addition to the procedures used to treat them. 

Developed by the World Health Organization, ICD-10 provides a more accurate definition of services and diagnosis than its predecessor ICD-9 and ultimately leads to more precise payments, fewer rejected claims, and overall improved disease management worldwide. While the benefits are clear, many U.S. healthcare organizations today are overtaxed with competing initiatives and are not realizing the resource requirements, planning considerations and operational challenges associated with a successful ICD-10 switchover.

While each organization’s implementation is its own unique case, the shear specificity and complexity of the new code set is a technological and operational challenge for any organization, no matter how prepared they may be ICD-9 contains around 18,000 codes and ICD-10 contains more than 141,000 codes. Remediation of ICD-10 will require extensive technology modifications to software systems, databases, reports, computing logic, data imports and extracts, and workflow procedures.

Extensive training and education will be required across many departments, and many providers fear that veteran coders near retirement will not stick around for the education and retraining, which could potentially be a huge loss in human capital. This challenge, combined with overall staffing shortages—particularly in the IT department—could lead to operational productivity loss across the organization. Additionally, the transition to ICD-10 is a significant financial burden to healthcare organizations, many of which are already budget strapped.

While the challenges prevail for organizations going through the switchover, the healthcare industry should not lose sight of the ramifications should they not meet the deadline or have enough time for testing before the official go-live. Claims backlogs, payment delays and denials due to coding and reimbursement discrepancies and a potential increase in fraud and abuse are just a few of the consequences should healthcare organizations not be fully prepared for the October 1, 2013 deadline.

ICD-10 is being compared to massive implementations in the past such as Y2K and HIPAA, yet many healthcare organizations have not initiated their path towards migration. While 2013 may seem far away, in reality it is right around the corner based on the magnitude of the transition. Taking the following steps to ensure proper planning and forecasting will help healthcare organizations transform a government regulation into a competitive advantage: 

1. Executive Leadership: Develop an appropriate Steering Committee, representing leadership from the various impact areas within the organization. The Committee will play a key role in guiding project scope, allocating the appropriate resources as well as maintaining the organizational focus necessary to complete the project. The Steering Committee is also responsible for setting the organizational Strategy for the implementation. This process includes indentifying the “Team” or project resources, which should include leadership, staff and potentially external vendors. The “Approach” should also be determined, including goals, scope and objectives. Finally, “Execution” should be clearly planned in terms of change management around people, process and technologies.
2. Impact Assessment: Complete an assessment of every department within the organization to identify where there will be an impact with the ICD-10 implementation. Some areas will not be impacted, while other areas will vary in their levels of impact. It is important to identify the range of impact levels so the organization can focus its resource efforts at the most severely impacted areas first and the least impact areas last. 
3. GAP Analysis: A GAP analysis is conducted on the areas of impact once an Impact Assessment has been completed. This step will help hospitals determine the difference between where they are currently and where they want to be at go-live through their strategic organizational strategy.
4. Contracting Guidelines: Contractual changes typically take the longest to complete because they involve multiple resources, organizations and personalities, resulting in lengthy negotiations.  It is important to review contracts early in the project timeline to determine if modifications are necessary to include terminology requiring compliance with the 5010 and ICD-10 regulations.  Vendors may also include additional fees to cover software implementation or maintenance expenses, therefore identifying early on required modifications to contracts as well as budgetary expenses.
5. Implementation Timeline: The project timeline should work back from the deadline date of October 1, 2013 and include completing the Impact Assessment, Gap Analysis, Vendor Contract Updates, Hardware Modifications, Software Modifications, End-User Training, Operations Re-engineering, Pilot Testing and Go-Live Preparation. During the GAP analysis and contract negotiations, vendor and contractor budget and timeline requirements are also determined. As there is not enough staff to make all modifications to test and integrate solutions simultaneously, each organization needs to schedule each modification per vendor so they are in line with the other changes occurring. A schedule of software testing should view like a waterfall to maintain a constant level of resource commitment as well as continue to progress toward the end goal.
6. Risk Assessment: A comprehensive risk assessment should be implemented to identify the level of risk the organization will experience while implementing ICD-10. Risk is related to outcomes not proceeding as expected and the result of such occurrences. A Risk Assessment will prepare for issues related to technology modifications, the revenue cycle, as well as coding and reimbursement discrepancies. Healthcare organizations should look to define and rank risks based on the probability and impact if each even occurred. Event ‘triggers’ and related responses such as contingency plans should be associated with each risk. Finally, resources should be assigned to manage the identified risks based on the trigger events and contingency plans throughout the implementation.
7. Budget: The budget should include four dedicated areas – Process Improvement, System Modification, Testing and Training/Change Management and Revenue Cycle Impacts.  Contractor fees and other supportive services should be considered and included in the overall budget.  Revenue Cycle impacts may include a reduction in coding productivity, increase in claims submission, and increase in claims rejections as well as variances in payment levels for ICD-10 codes compared to ICD-9 codes.
8. Testing: Working closely with vendors, develop a detailed testing plan that includes expected results and outcomes, resources, specific testing for software, and hardware and support services. The testing should be closely tracked according to expected results and monitored to determine whether each function passes or fails each step of the way. Testing activities should be scheduled with both internal and external resources and locations. The last thing the organization wants is an end-user that is scheduled for a day of testing only to get a software error within the first hour and give up losing hours of productivity. Having vendor technicians on-call to support such events and track progress daily will ensure the organization stays on track with testing schedules.
9. Prepare for Go-Live: Go-live is not a one-day occurrence, but rather a series of events to help hospitals prepare for the many people and systems that need to be functioning at a specific level by October 1, 2013.  The Go-live plan should identify all participants, and define roles and responsibilities, tools/resources, activity milestones and timelines, contingency/back-out plan, support contact information and a reporting process for any issues.  Pilot Go-Lives have proved to be beneficial to other countries that have implemented ICD-10. Using this method in the healthcare organization’s roll-out plan will identify and resolve issues early on and maintain a manageable schedule.
10. Post Go-Live: Following Go-live, organizations will be busier than they were to prepare for the organization. However, now is not the time to forget how much work was accomplished and what was learned along the way. Each organization should summarize project results, evaluate success against established criteria, identify the key lessons learned and assess the project for future improvement.

While all these steps are critically important, organizations can not lose sight of the importance of testing before go-live. Depending on the size and scope of the project, organizations should begin testing anywhere from 2 years – 6 months before the deadline. Virtually every system that touches an ICD-10 code has to be modified, and the longer organizations take to get started on the implementation, the less time they have to test.

The implementation of ICD-10 seems overwhelming and expensive; however, the benefits of implementing this modern code-set far exceed the costs. Currently the U.S. is the last industrialized country to implement the ICD-10 codes, limiting the collaboration and data details that can be exchanged worldwide related to healthcare issues. The more complex code set also allows for specification in reporting healthcare data that will result in newer and more advanced disease identification and treatment methodologies. In addition, ICD-10 enables an increase in detection of fraud and abuse as a result of the data contained within each claim transaction. These benefits will be the foundation for health transformation as we move more aggressively toward technology implementations throughout the U.S.

About The Author

Ms. Sullivan has over 10 years experience leading strategic healthcare projects, including an ICD-10 Impact Assessment for Centers for Medicare & Medicaid Services and EHR Implementation projects for clients throughout the US. Ms. Sullivan chairs the HIMSS ICD-10 Task Force and leads business development and delivery projects within Capgemini’s Healthcare sector based in Atlanta, Georgia.