ICD-10 Implementation Planning – Where Do We Begin?

These are the planning phases to consider in preparation for the ICD-10 Implementation.  Each of these four phases will outline time frames and steps you should take to better prepare  for the October 1, 2015 deadline.  You may consider partnering with an EMS Consulting Firm familiar with ICD-10 to help you develop a plan and navigate your company through the steps.

Phase 1 – Implementation Planning:

Start by assembling an Implementation Team.  This team should consist of representatives
and decision makers from the following departments:

  • Billing/Coding
  • Finance/Accounting
  • Clinical
  • Education
  • Quality Assurance/CQI
  • IT Department
  • Senior Management

Now that you have your implementation team in place, it’s time to start formulating a plan. Phase 1 is the pre-implementation stage and should be completed between the first quarter of 2013 and the second quarter of 2013.  If you haven’t already begun preparations, don’t panic.  You should have your implementation team assembled and working through these steps by the end of this month. Your implementation team should plan to meet monthly and discuss the progress of each step in this phase.

  • Establish deadlines for each phase – meeting the deadlines of preparation for each stage is critical to the success of the transition
  • Identify Resources – establish what resources are available to aide in the transition
  • Impact Assessment – discuss what effects your organization may expect in the months following the implementation date (cash flow interruptions, increased denials, etc.) and
    formulate a plan to continue business operations if the money suddenly stopped
    coming in (discuss the need for a dedicated line of credit)
  • Initiate Dual-Coding – your billing department should begin dual-coding in preparation as soon as possible
  • Begin Documentation Audits – Compile a list of the most utilized ICD-9 codes and map these codes to its ICD-10 counterpart.  Audit the documentation to see if the documentation is specific enough to support the ICD-10 code.  (This will highlight the areas that need attention during documentation training)
  • System Upgrades – determine if additional system updates will be required and set a deadline for implementation
  • Coder Training – determine where training can be obtained and register each member of your billing staff
  • Coder Materials – determine what materials your billers and coders will need.  Consider ICD-9 and ICD-10 coding books and EMS quick coder materials.  Make plans to purchase these tools as soon as they are available
  • Documentation Training – discuss the approach and formulate a plan, including updates to your current ePCR software applications

Phase 2 – Implementation Preparation:

Phase 2 involves actionable items developed in Phase 1 and should be completed by the fourth quarter of 2013 but no later than the second quarter of 2014.

  • Documentation training should be well underway
  • Coder training should be completed or near completion
  • Dual-Coding should be in full swing and coders should be more proficient
  • Continue documentation audits using dual-coding initiatives
  • Set deadlines for EDI testing

Phase 3 – GO LIVE!:

Phase 3 involves actionable items developed in Phase 2 and should be completed by the first quarter of 2014 but no later than the third quarter of 2014.

  • This is it!  This is what all of the planning and training has led up to.  All of the practice and dress rehearsals have lead up to this moment.  It’s show time!
  • Begin submitting claims with ICD-10 codes to payers who are ready to accept them
  • Closely monitor claims sent with ICD-10 codes for payer activity and trend patterns

Phase 4 – Post-Implementation Follow Up:

Phase 4 involves intense follow-up to monitor for patterns in the revenue cycle and
unforeseen challenges that have been discovered.  This phase should be monitored from the fourth quarter of 2014 through the fourth quarter of 2015.

The Major Differences Between ICD-9 and ICD-10:

The impending change from ICD-9 to ICD-10 will be the largest and most challenging transition of our careers.  When it comes to ICD-10, a good plan is important to your success.  Have you formulated a plan yet?  If not, don’t panic but be prepared to roll up your sleeves and get busy!

You may be wondering why it’s important to start preparing 13 months in advance. There are many steps in the preparation so the more time you allow, the better the result will be. Think of the preparation as dress rehearsal for the live show. The more rehearsal time you have, the better the live show will be. The same applies here because the financial health and very survival of your business depends on a flawless live show.

Let’s start with understanding what the major differences between ICD-9 and ICD-10 and how this will affect your daily operations during and after the transition.

ICD-9 Codes:                                                      ICD-10 Codes:

14,000 Diagnosis Codes                                      70,000 Diagnosis Codes

3-5 Characters in Length                                    3-7 Characters in Length

Digit 1 may be Alpha or Numeric                     Digit 1 is Alpha

Digits 2-5 are Numeric                                       Digits 2-3 are Numeric

Lacks Laterality                                                    Allows Laterality and Bilaterality

This transition will have significant challenges and will be the largest transition the healthcare community has ever undertaken. This will impact all areas of operation: billing processes, clinical documentation, workflow structures, quality reporting, revenue cycle and employee retention.

Preparation for this transition can help mitigate the impact.  There will be a learning curve with this transition so adequate training, patience and encouragement is paramount.  You can expect cash flow interruptions, an increase in denials, a significant decrease in productivity and employee burnout.

EMS Providers should begin preparing for strategies to accommodate decreases in billing staff productivity during coder training and in the months following the implementation date.

Completion of clinical documentation may result in decreased productivity and increased frustration as clinicians modify their documentation practices to accommodate the increased specificity required with ICD-10.

Not only will EMS Providers be impacted by this transition, Payers and Clearinghouses will also have to make significant adjustments.  System updates will be required to handle longer code sets and dual coding sets.

Every National Coverage Determination (NCD), Local Coverage Determination (LCD) and payer policy that is tied to medical necessity will have to be revised, thereby creating new payment rules and coverage determinations.  Your company will need to identify and adapt to these new policies and prepare for an increase in denials, appeals and underpayments.

What can you do to get ready?  Preparation is important in making a successful transition from ICD-9 to ICD-10.  There are steps your organization should begin taking as soon as possible to lessen the impact of the transition.  These steps will be outlined in further detail in a future blog post.

Remember, when it comes to ICD-10 preparations, your organization is either preparing to success by taking proactive steps or preparing to fail by doing nothing.