The Ticlio mountain pass in Peru elevates to approximately 16,000 feet; a semi-truck without cargo carries a heft of nearly 16,000 pounds; and the tenth edition of the International Statistical Classification of Diseases and Related Health Problems (ICD-10), with the use of optional sub-classification, is projected to produce more than 16,000 unique code sets for medical classification. The burden is obvious: No matter how it’s measured, 16,000 units of anything always signifies a lofty, weighty contest ahead.
For physicians, the hefty trial is a WHO-done-it affair — prosecuted by the World Health Organization with firm backing from the Centers for Medicare & Medicaid Services (CMS) — and once the gavel hits on Oct. 1, 2014, compliance for all practices is paramount. While a number of physicians have already geared up for the gruel, some remain ICD-tender as ICD-10 implementations loom. It was mostly to this latter group of professionals that Jonathan Handler, MD, CMIO of M*Modal, and Mike Costa and Jason Fortin of Impact Advisors directed their advice regarding ICD-10 and ICD-11 concerns, citing several transition points which could be used to ease the process across the practice spectrum.
“I think ICD-10 and ICD-11 will have varying impact on practices depending where they are today, and whether the government decides to delay or skip ICD-10,” Handler said. “For a practice already ICD-10 ready, there may be very little near term change. For the practice using ICD-9, there may be very little near term change if the switch to ICD-10 is abandoned in favor of ICD-11, which [I believe] is not even due for beta release until 2014 and full release until 2015. There will be training, process change, and often software upgrades or modifications for practices using ICD-9 today if mandatory conversion to ICD-10 is not delayed.”
Costa and Fortin also noted the divide regarding the stages of preparation.
“CMS has proposed a one year delay to the deadline for compliance with ICD‐10,” they said. “For organizations that were already behind schedule, the delay is typically seen as a blessing. For those that had already taken many of the steps toward compliance, the delay is typically seen as a risk that may increase cost, reduce momentum, and shift organization priority toward other, more pressing initiatives. And for others it simply means they’ll have a little more time to get everything right: system upgrades, testing, education and training. Provided that stakeholders continue to work on required preparations, the delay should hopefully result in a smoother transition -- fewer rejected claims in the first few months, limited losses of productivity, etc. That being said, more progressive organizations are taking the approach of continuing to drive toward remediation as if the deadline of October 1, 2013 will remain in place.”
The Impact Advisors representatives spoke of the need for more industry focus on a massive scope issue like ICD-10 implementation.
“The most common hiccups we’ve seen are a lack of provider focus on ICD‐10 compared to other major industry initiatives, such as the creation of ACOs and meaningful use remediation, for example; lack of getting business partners engaged and working proactively to prepare, coordinate and test for compliance; and a lack of sufficient focus on evaluating and improving clinical documentation,” Costa and Fortin noted.
Fortin and Costa provided three major improvement efforts that could be made by physicians to help alleviate industry hiccups.
1. Document and mean it. “Physicians should be especially aware of the increased demand for documentation specificity in order to support optimal ICD‐10 coding and the maintenance of reimbursement levels,” Costa and Fortin said. “The typical organization we’ve worked with requires a significant increase in the volume of documentation needed today in order to optimally code using ICD‐9. Migrating to ICD‐10, with its dramatically larger set of codes, will require that much greater an effort. This ultimately will have implications on a physician’s time and productivity.”
Without documentation methods up to par, coders and the system can do little to improve the practice management and productivity.
“We suggest providers carefully review their clinical documentation to understand how comprehensive it is today and where the biggest gaps exist, so those areas can be focused on. This may include the creation of a clinical documentation improvement program to not only enhance documentation but ensure it continues to improve over time. Provider participation and championing of such programs is critical.”
2.) Keep business partners engaged. Although the task may not be simple, Costa and Fortin reiterated the importance of keeping business partners in the loop.
“Business partners ultimately need to work together, and this requires regular communication and coordination, especially for providers that will need to manage multiple compliance upgrade and testing windows among their staff. We suggest providers reach out early and often to their partners and remain persistent in their request for responses to their ICD‐10 related questions. There is often no shortcut around this.”
3.) Raise awareness and ask the right questions. “Raising awareness of the potential implications of a failure to achieve ICD‐10 compliance is the most effective remedy we’ve seen for increasing the prioritization of an organization’s remediation efforts. ‘What does it mean if we fail?’ ‘How much reimbursement will be left on the table?’ These are questions that tend to get leadership’s attention, and help raise the recognition of ICD‐10 as a strategically imperative initiative rather quickly,” Costa and Fortin added.
Following groups such as AHIMA, HIMSS, WEDI, ICD‐10 Watch and 3M can suitably achieve this aim. Going straight to the source, CMS, is also recommended by Costa and Fortin to increase knowledge of all that is ICD-10.
Despite the talk of ICD-11, Fortin and Costa encouraged physicians to continue preparing for ICD-10 to ensure compliance regardless of future coding initiatives.
“The option of foregoing a transition from ICD‐9 to ICD‐10, and instead waiting for ICD‐11, was an alternative that was considered by the U.S. government,” the Impact Advisors concluded. Release [for] the basic ICD‐11 medical code set until 2015 at the earliest. From the time of that release, subject matter experts state it would take anywhere from 5 to 7 years for the United States to develop its own ICD‐11‐CM and ICD‐11‐PCS versions and hence wouldn’t be feasible for the industry. For these reasons we recommend organizations plan to proceed with ICD‐10 versus considering a direct to ICD‐11 approach.”
Handler took a less direct route, finding that in the same way that ICD-10 is expected to improve the descriptiveness of ICD-9, ICD-11 will surely do the same for its pending predecessor in a far shorter timeframe.
“ICD-11 is due for release in just a few years, and it is designed to address many of the gaps and problems inherent in ICD-10,” Handler noted. “It is not clear that the cost and disruption required to switch to ICD-10 is adequately offset by the benefits. With ICD-11 just around the corner, many have concluded that it makes more sense to skip conversion to ICD-10 and just move straight to ICD-11. It is not known how the government will respond to the conflicting recommendations regarding adopting vs. delaying ICD-10.”