If you haven’t begun to address ICD-10 at your organization, it’s time to start conversations and devise a plan. Although I expect to continue seeing chatter about further ICD-10 delays, I believe we’ve reached critical mass with organizations supporting October 1, 2014 as the unmovable implementation date. Most recently on July 11, 2013, both the American Hospital Association (AHA) and the Blue Cross and Blue Shield Association (BCBSA) indicated to Congress that they oppose any action seeking to further delay the October 2014 deadline (see article).
To start conversations at your organization, I suggest focusing on five key areas. Every organization is unique; as such, an appreciation that ICD-10 compliance can have multiple approaches will be helpful:
- Sponsorship: Have you identified who your Executive Owner will be?Some organizations have landed with the CFO, others with the CIO or COO. Wherever you land, it is important to recognize that ICD-10 cannot be implemented by any one area…it’s a shared responsibility with organizational impact. You’ll need an Executive Owner to ensure it success.
- Gap Analysis: Do you know where ICD-10 needs to be implemented, and what you need to “fix?”Many organizations have generated lists in in all business areas – including IT – to determine scope, timeline, and staffing needs. You’ll want to make sure you consider business processes, job aides, and recurring training classes. A thorough gap analysis expands well outside of IT!
- Testing: Have you determined the extent to which you’ll test, and measure success or risk?Many organizations think of testing as an IT function; however, ICD-10 testing should largely be considered a business function. Long before your IT systems are remediated you can begin coding or adjudicating claims in ICD-10 to help forecast financial risk. A good ICD-10 testing approach will include some manual testing with reasonably extrapolated results.
- Training: Do you know the pockets of individuals within your organization that will require detailed training vs. overview training; and, have you considered training external constituents?Every organization has a unique blend of skills that will require a unique approach to refine. Many organizations are defining upwards of six training levels at varying degrees of detail. Some organizations are even opening their training sessions to external constituents that play a key role in an end-to-end business process. The key is to consider the source of ICD-10 data, its generation, and its use.
- Post-Production Support: As you transition your production work to ICD-10, are you defining an approach to address the obvious mishaps and look for the obscure ones?High-volume services and denied claims will be the obvious areas where “mishaps” will occur with ICD-10 coding and claim adjudication…they are probably already on your radar. You’ll want to consider a means to, at least temporarily, address low-volume services and underpaid claims that can add up to big problems over time. ICD-10 will impact specialties and benefits to different degrees, and you’ll want to do your best to avoid being surprised if something that is traditionally off your radar becomes a big deal.
Best of luck with your compliance efforts, I hope this helps you start the conversations!