The latest ICD-10-CM/PCS implementation delay should be used by healthcare providers to “reflect, regroup, and revitalize” as well as finally “get the transition right” and mitigate risks caused by inadequate preparation, said Sue Bowman, AHIMA’s senior director of coding policy and compliance, during testimony Tuesday to the National Committee on Vital and Health Statistics’ Standards Subcommittee.
“We understand that many organizations did not leverage the opportunities presented by the last delay to prepare and transition to ICD-10,” Bowman said in her testimony. “It is essential for all stakeholders and organizations to take advantage of the opportunities provided by this recent delay.”
AHIMA was invited to testify to the subcommittee in Washington, DC on issues related to the one year delay of ICD-10-CM/PCS implementation enacted in April by the Protecting Access to Medicare Act of 2014. The subcommittee asked participants to comment on the main challenges and risks associated with the ICD-10 delay, as well as the cost implications, contingency plans being developed by organizations to deal with the delay, and what can be done to ensure no further delay is enacted. In addition to the verbal testimony, AHIMA submitted written testimony answering all of the NCVHS subcommittee members’ questions.
Main challenges associated with the delay include a loss of forward implementation momentum and stakeholder attention, skepticism regarding the firmness of the October 1, 2015 compliance date, increased implementation costs, and a re-direction of ICD-10 budget to other activities, Bowman said.
“A significant industry-wide risk is that entities that were already behind in their ICD-10 planning and preparation won’t use this additional time in order to catch up,” Bowman said, “and entities that may have been on track for the 2014 compliance date will fall behind as a result of some of the challenges I just mentioned.”
Delay ‘Disruptive and Costly’ for Healthcare Organizations
Five and a half years after the final rule adopting ICD-10 was published in 2009, the US has still not implemented ICD-10-CM/PCS. This latest one-year delay, like previous delays before it, is “disruptive and costly for healthcare delivery innovation, payment reform, public health, and healthcare spending,” Bowman’s testimony stated.
The financial investment put into preparing people and systems for ICD-10 has been harmed by the delay. Some healthcare stakeholders expect the most recent delay will increase their ICD-10 preparation costs by 30 percent due to the need to retain coders and sustain implementation efforts for another year, Bowman testified. This does not factor in the other costs incurred through using the “out-of-date and imprecise ICD-9-CM code set.”
Suggested Areas of Focus During the Delay
Bowman outlined several top priorities healthcare organizations can focus on leading up to the new ICD-10 compliance date of October 1, 2015—clinical documentation excellence, education, and increased testing internally and with payers. Doing so will minimize the impact of the code switch on coder productivity and coding accuracy, and lead to reduced claim denial rates and higher quality health information, she said.
Other areas of focus over the next year should include:
- Increasing engagement with physicians and their staff, ancillary departments, and post-acute providers to ensure all stakeholders are moving toward ICD-10
- Evaluating and resolving ICD-9-CM coding and documentation issues
- Leveraging technology to provide real time documentation improvement tools that facilitate documentation at the point of care
- Developing a more thoughtful and comprehensive educational plan
- Analyzing data to identify and focus on high-risk documentation and coding areas
How to Prevent Further Delays
No further delays of ICD-10 implementation should be enacted so US healthcare organizations can “start realizing the benefits of better data as well as control implementation costs,” Bowman said. To prevent further delays, AHIMA recommended that the Centers for Medicare and Medicaid Services (CMS) work with public and private sector organizations to broaden awareness of ICD-10 and dispel misunderstandings and myths that may exist about the code set.
Other AHIMA recommendations included:
- CMS helping lead efforts with stakeholders to educate members of Congress and key White House staff on the value of ICD-10, as well as the consequences of delay
- CMS working with stakeholders to offer training, education, and technical assistance, including the development of customized resources, to help “at risk” providers such as small physician practices, rural providers, and critical access hospitals prepare for ICD-10
- CMS working closely with public and private sector stakeholders to ensure comprehensive and ongoing end-to-end testing for ICD-10
“Active engagement and commitment by all stakeholders is essential to preventing another delay and transitioning to ICD-10 smoothly,” Bowman said. “To be prepared for ICD-10 implementation in 2015 and to mitigate risks presented by the ICD-10 transition, it is imperative for all healthcare organizations to remain fully committed and ‘stay the course’ on ICD-10 planning and preparation activities.”