Are you ready now for ICD-10?
October 1 is now only weeks away and most physicians and hospitals are busy finalizing their ICD-10 preparations. CMS and AMA have provided some “flexibilities” for Medicare coding and medical billing but the onus remains on providers, billers and coders to be ready.
While there are no shortcuts, we offer a checklist to assure that you are ready:
- Train staff
- Train physicians
- Verify that all systems are updated
- Review payer contracts and procedures
- Financial contingency planning
- Test, test, test
By now, hospitals and physician groups should be busy training each employee. If not, creating a plan and getting started is an urgent priority.
Training for coders should be complete by now so that they can be helping others learn, and be doing “dual coding” of selected encounters or cases.
If coding is done by an outside party, you should be familiar, and comfortable with, their training plan with confidence in their ability to be ready.
Yes, physicians must participate in the training process. ICD-10 challenges the way many physicians document, demanding a greater level of specificity. Best practices include:
- A list of your most common 10-20 ICD-9 diagnoses that compares current documentation to ICD-10 requirements. Strengths and weaknesses from this analysis should already be incorporated in your provider training.
- A completed audit of current documentation to find patterns of missing information. Specialists should already be working with their referrers to make sure that orders have sufficient detail for ICD-10.
- Updates to templates in EHR systems or paper-based templates should be complete to guide ICD-10 documentation in common clinical areas.
Physicians who have coding done from dictated reports should already have extensive feedback from their coders about whether their dictation is sufficient for ICD-10.
Verify that Systems are Updated
Practice management, EMR, billing and other systems should all be upgraded by now: to store and transmit both ICD-10 and ICD-9 codes. If not, a firm upgrade schedule must be in place over the next few weeks.
Maintaining both ICD-9 and ICD-10 is critical so that claims may be submitted both before and after October 1. Practices and hospitals that participate in clinical trials or research studies will also need to have both coding systems available.
It is of utmost importance that all systems are tested well before October 1. Testing at the last minute will be risky, as there are always issues to iron out and vendors and insurance carriers are highly likely to be back-logged in September.
ICD-10 transition terms and schedules should be in vendor contracts. This includes being clear about incremental costs, including testing.
Review Payer Contracts and Procedures
Insurance contract negotiations need to include ICD-10 so that services billed with ICD-9 are covered when ICD-10 is in effect, and at the same rate. In the future, carriers are expected to change their rates to be in line with more specific ICD-10 codes.
It is also critical to stay in close touch with your major payers to know which will not be ready. We saw this with 5010, where some carriers were not ready on January 1, 2012 and billing had to be via 4010 until their systems could accept 5010. If you use a billing service, this is an area they will handle on your behalf.
Financial Contingency Planning
Hospitals and physician practices must have an existing budget to implement ICD-10 including:
- Software modifications,
- Education for physicians, coding staff, etc.,
- Testing, and
- Potential temporary staffing to assist with increased work during the transition.
Contingency planning should include a plan for possible cash flow interruptions. One common approach is a bank line of credit (LOC). Many experts recommend a reserve of 2 to 3 months of cash flow. The LOC must be established in advance of the need because it is much easier to get the LOC when the hospital or practice can demonstrate a steady cash flow than when cash is delayed. However, many LOC’s have a fixed term, often 12 months. Therefore, the optimum time to establish the LOC is now.
Test, Test, Test
ICD-10 preparation must include extensive testing prior to October 1. The most obvious testing is with systems, especially those that affect payment. Unfortunately, testing with insurance companies depends on their testing schedules. Whether your billing is done in house or by a billing service, make sure the testing is on schedule and monitor the results.
Testing of staff and physicians may be more challenging since it can’t be done too soon but it must be done far enough in advance to correct any issues identified. One best practice is to perform “dual coding” for a select period of time: i.e. create ICD-9 codes needed for current operations and ICD-10 at the same time. While this approach is not always feasible, it will identify many issues that can be fixed before October. An ideal timeframe for dual coding is now.
Whether we personally “like” ICD-10 or not, it is a pre-requisite for many advancements in healthcare. But these longer term benefits come with short-term costs that must be addressed now. This article has outlined the major steps that hospitals and physicians need to take now to successfully implement ICD-10 on October 1. While some issues are sure to arise, organizations who take these steps will find the transition much easier than those who do not prepare adequately.