ICD-10…the Y2K or our era?

Well, all of the anxiety over and the day of coming and going. Was it all for nothing? Some people I have met and spoken with talk about it in Y2K tones. I think differently. While I always wanted to be a part of a Y2K type initiative, I recall how much work effort went in to getting us stable with ICD-10.

It’s not as easy or straight forward as people like to make it sound. There was the operational, clinical, ecducational and information technology aspects of it that were so all encompassing that it was difficult to ignore. When Congress and CMS kept postponing it at the behest of the AMA and their lobbyists and Physician politicians said that it would be the end of the world if we did implement it, it caused billions of dollars to be wasted in getting us to ICD-10 a year or two ago. Now that we are finally here and we have survived (and yes, patients are still around and need medical attention and doctors are too), we look back at what has been quite an eventful couple of years with great satisfaction, knowing that it wasn’t all for nothing.

We need to see how claims will be like and the revenue cycle processes that will take over now and see how those survive with the ICD-10 Tzar and his team at CMS.

It’s an ICD-10, ICD-10, ICD-10 World!

walked-into-lamppostRegardless of all of the humorous codes that we have grown to chuckle at over the last few years, we are now finally in an ICD-10 World. Today, October 1st, 2015 would have been the end for some of a few years of their lives. Similar to the world of Y2k, this will be the culmination of a lot of work that many people (including yours truly) have worked on these last few years. Let’s thank all of those healthcare information technology professionals, analysts, go live support and adoption teams who have made this possible, all for the cause of better patient care. There has been thousands of hours that have been put into transitioning our nation’s healthcare providers and payers to ICD-10 so that we can finally get on to a 21st Century diagnosis terminology. It certainly has been quite a ride.

ICD-10 Goes live October 1st 2015

Finally! After all these years, one announced delay by CMS and hundreds of thousands of hours of work effort, we are on the doorstep of ICD-10! I had the privilege of working on this project from planning to execution at my healthcare provider and it was something like the equivalent of the Y2K project. We reviewed the application inventory, reached out to the vendors to understand their plans, worked with our EMR vendor to understand the way in which we needed to see which records in the system that we need to update and then reviewed those to understand what the work effort would be. We identified our team members, put together a project charter, a master test plan for our pre-test, unit test integrated testing rounds 1,2, 3 with the payers and finally User Acceptance Testing with the providers. We built our project management protocol and work breakdown structure and kicked off the project.

With all of the testing that has hopefully happened within healthcare provider and payer organizations this year, ICD-10 codes should be good to go when you go to the doctor and they then file a claim to get your ambulatory visit or inpatient treatment paid for by insurance, but nevertheless, you may want to wait a while if your visit isn’t of an urgent nature; just in case the physician has forgotten how to use that new tool in the EMR system that helps them with putting in the right specificity for the diagnosis that they used to remember the old ICD-9 code for the last 40 or so years.

Hopefully by now, healthcare provider organizations have kept about 6 months of reserves on hand or have worked with their financial institution to have those funds available to them in case they are required due to claim backlogs. Time will tell through financial reports whether their is truly concern about whether ICD-10 codes are revenue neutral for the organization or not.

Commanding your ICD-10 Go Live! Are you in command yet?

ICD-10 is about two weeks away and your in the last stages (or not) of putting together your command center and go live to support your healthcare organization’s transition to the world of ICD-10 specificity. The ICD-10 Command Center should ideally be staffed with Subject Matter Experts (SME’s) in Information Technology as well as Administrative/Operational and Clinical representatives who record all identified issues and will manage the support processes during the go-live transition.

The Command Center will ensure that the appropriate communication of the go-live progress occurs among the end users and leadership of the healthcare organization prior to, during and after October 1st, 2015. For your command center, you need to think about having:

  1. A Dedicated room or location(s) that you will have to co-locate your SMEs
  2. Cell Phones for the “At the Elbow Support” team members who will be supporting the physicians
  3. Laptops for the staff to work on issue resolution
  4. White Board/Flip Chart to record issues and resolutions or Incident Reporting Tools/Technologies
  5. A dedicated phone number(s)/”hot line” for the ICD-10 Command Center that you broadcast to the organization in the run up to the go live and continuously remind through daily status communication
  6. Beverages and food for the command center team that will be at that site during the day (and possibly nights for areas such as ED)

Your physicians will be impacted in the following ways after they complete their ICD-10 physician education by this month:

  1. As a result of the need to complete education and need for increased specificity of their documentation
  2. Their future orders for procedures that occur after October 1st, 2015 must contain ICD-10 diagnosis codes.
    3.Clinical Documentation Improvement queries will create an additional workload on physicians starting in October and
    5.Physicians will begin to select ICD-10 codes October 1st through some sort of job aid that most EMR vendors have included in their software to help mitigate the impact of ICD-10 specificity.

Each organization has different ways in which they are dealing with ICD-10’s regulatory go live on October 1st.

Patients too will be impacted by ICD-10 go live.

There might be possible delays in being seen by their doctors, backlogs by physicians that have not planned ahead, delays by their healthcare payers (insurance companies) in making payments to the provider (hospitals) may cause patient frustration and delay in payments. While we all plan for the worst, but hope for the best, here’s wishing for the best outcome possible for ICD-10 starting October 2015.

ICD-10 – How far we’ve come!

It’s still a surprise to me that we are actually here. It’s coming up to the end of July 2015 and we are closer to ICD-10 Go Live than anytime before. I’ve heard of one organization regionally that is still surprised we got here and are scrambling to get their work done. Others have been working on this for a few years and have put in more efforts over the last 7-8 months to prepare for this event. Many physicians can’t believe that we have come this far and are now concerned that they don’t have the tools and training to be ready for ICD-10 go live. What will the world look like on October 1st, 2015?

There are some vendors that are keeping their customers guessing about remediation of the systems and have their remediation requests in a long queue. Have you increased the real estate on those reports and extracts that you publish? Have you tested your main EMR and have you established your plans for command center for the go live? Are your organizational priorities focused on ICD-10 and maybe one other initiative? These are the questions that operationally and in IT, that leaders are dealing with right now. If they are not, then they have to do some soul searching as to how did they get to this status.

Healthcare IT News reported recently that the Centers for Medicare & Medicaid Services announced that it would work with the AMA on steps to ease the move to ICD-10 and that CMS will adopt suggestions made by the AMA with regard to the code set conversion. Those changes cover i) Claim Denials  ii) Quality Reporting and other penalties iii) Payment disruptions and iv) Navigating transition problems where CMS will create a communication or command center as well as a Tsar of ICD-10 to assist and triage provider related issues or concerns and be able to resolve issues caused by the new code sets.

Below are the points directly from Healthcare IT News:

1. Claims denials. “While diagnosis coding to the correct level of specificity is the goal for all claims, for 12 months after ICD-10 implementation, Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family,” CMS officials wrote in a guidance document.

2. Quality reporting and other penalties. “For all quality reporting completed for program year 2015 Medicare clinical quality data review contractors will not subject physicians or other Eligible Professionals (EP) to the Physician Quality Reporting System (PQRS), Value Based Modifier (VBM), or Meaningful Use 2 (MU) penalty during primary source verification or auditing related to the additional specificity of the ICD-10 diagnosis code, as long as the physician/EP used a code from the correct family of codes,” CMS explained. “Furthermore, an EP will not be subjected to a penalty if CMS experiences difficulty calculating the quality scores for PQRS, VBM, or MU due to the transition to ICD-10 codes.”

3. Payment disruptions. “If Medicare contractors are unable to process claims as a result of problems with ICD-10, CMS will authorize advance payments to physicians,” AMA president Steven Stack, MD, noted in a viewpoint piece on the group’s website.

4. Navigating transition problems. CMS intends to create a communication center of sorts, including an ICD-10 Ombudsman, “to help receive and triage physician and provider issues.” The center will also “identify and initiate”resolution of issues caused by the new code sets, officials added.

Interview with a CAC PM – ICD-10 Beware!

It’s been some time since I shared my thoughts as we are well into 2015. ICD-10 for many organizations is well under way and I thought that it might be good to hear from folks other than myself once in a while. So I connected with my good friend and colleague whom I worked with last year, Paul Arel.  I had the chance to sit down with Paul and talk about our recently completed engagement working together at a provider organization last year. We discussed his experience with a Computer Assisted Coding (CAC) product that is getting a lot of attention due to the ICD-10 Transition.

Ajay:  Thanks for sharing your thoughts on CAC. You’ve been working in other verticals before you got into healthcare IT recently. Tell me the origin of how you started on your recent CAC project?

Paul: My pleasure Ajay. As you’re aware, I have been in the healthcare IT sector for a number of years. When our provider client started its enterprise-wide implementation of a vendor’s CDIS and CAC products to get ready for ICD-10 implementation, they planned on a 3-year project. With about 3 months planned project schedule left, they were having misgivings about the project’s true status and hired me to come in as the new Project Manager. My first task was to get familiar with the project and its players, then ascertain the project’s true delivery status. In so doing, we ended up adding another year onto the project’s delivery schedule.

Ajay: Who were your primary stakeholders and what was their involvement?

Paul: This implementation grew out of the Revenue Cycle side of the hospital. CDIS (Clinical Documentation Improvement System) is utilized by the case reviewers during the patient’s hospital stay. The software helps reviewers make sure that treatment for ailments/injuries follows a path of documented diagnoses. CAC is utilized by the coders to generate billing codes for all care that is given to each patient during their visit or stay. The two work hand in hand to correlate patient care with diagnoses and billing codes, maximizing the revenue stream for the hospital system and driving compliance with the Affordable Care Act. Because of the over-reaching nature of the software and its implementation being enterprise-wide, the stakeholders were numerous and diverse. I would say that the primary stakeholders were the software end users themselves. End user management and the IT support staff were intimately involved in the planning, testing, implementation and monitoring (problem resolution) at every turn during the project. At any one point in time, there were roughly 60 stakeholders intimately involved in the project’s implementation.

Ajay: What was your main challenge especially with the vendor?

Paul: Our main challenge arose as the organization began to realize the gap in knowledge for implementation of the CAC/CDIS products on the scale that the hospital system needed. The chosen software appeared to not be mature at the project’s inception and the disparate EHR systems that the organization used in different markets created a troubling scenario for implementing this software as a standard throughout the organization. At the time, the CAC vendor appeared to have no prior implementation experience on this large and complex an installation, so much of  the implementation was learn as you go for everyone involved, including our CAC vendor and the various other vendors.

Ajay:  Besides the change in ICD -10 dates by the government, what were the main risks associated with your project go live?

Paul: Risks certainly evolve during a project’s life, but, hands down, the biggest over-riding risk was indeed the interoperability of the  software systems involved. While the HL7 standard has been a giant stride forward in interoperability, there still exists much work to be done as the need for pieces of software to communicate as part of a larger whole are constantly expanding. At some point in time, healthcare will require its software vendors to blend their software into a homogeneous system that should appear to the end users to be a single, common interface on the EHR level. At the same time, it needs to allow Operations and Revenue Cycle to pull relevant data from any of the subsystems effortlessly.

Ajay: What issues did you face? Any consistent ones throughout the project?

Paul: Personnel availability was probably the single biggest issue on numerous fronts. Starting with the CAC/CDIS vendor and including most all of the other vendors involved and even within the hospital system itself, personnel availability was the biggest ongoing obstacle to implementation. Most organizations had their personnel “all hands on deck” with the myriad of work needed to test and become ICD-10 compliant in all aspects, as well as performing their regular duties. Congress postponing the ICD-10 implementation date confused and compounded the problem for everybody. And the additional postponement only makes the situation much more problematic for planning in 2015. It is a nightmare right now for all healthcare organizations trying to plan personnel needs for 2015. Nobody knows exactly which personnel will be needed, how many of them will be required, who will be available and, ultimately, if Congress will pull another bonehead move to delay ICD-10 implementation yet again.

Ajay: Bonehead indeed! Healthcare Provider organizations have spent billions to date and hopefully the ecosystem realizes that. Ultimately it’s you and I and the patient population of the United States that pays for all of that.

Ajay: Did you have any outside training organizations train the coders?

Paul: End user training was conducted by the CAC/CDIS vendor, as part of their contract with the organization for implementing their software. Additional training was conducted by Revenue Cycle staff and additional training is also available as part of the vendor’s ongoing usage contract.

Ajay: How was the implementation of the software left, in the wake of the ICD-10 delay?

Paul: The software is designed, like many of its kind, to be compliant for both ICD-9 and ICD-10 usage. When the project ended, the provider organization was utilizing the software in ICD-9 mode only. Provisions were underway to continue with ICD-10 training and the roll-out of dual coding (ICD-9 and ICD-10 coding simultaneously) to help familiarize end users with ICD-10 coding before the nation transitions.

Through another project, we tested ICD-10 functionality, but, as with most hospital systems, a thorough end-to end, integrated test of ICD-10 is still necessary. Hospital systems not only need to be certain that ICD-10 codes pass through their software systems, but that the reimbursements they receive are truly being maximized under the new ICD-10 system. There needs to be validation on two fronts: 1) that the care each patient receives benefits their well-being in the most efficient manner, and 2) that the patient stay generates the maximum return on the dollar for the hospital system. Combined together, these two aspects will drive the hospital system towards providing the best possible care for all patients today and in the future. Despite the politics behind the Affordable Care Act and how/when it is implemented, I feel that this is the underlying goal of both healthcare providers and the government.

Ajay: Thanks for your time Paul. All the best for 2015 and beyond.

Paul: Thanks Ajay. Same to you.

About Paul Arel:

image

About Paul:

Paul Arel, PMP, MCSE, is a Senior Information Technology Project Manager with over 10 years of experience in project management, having spent much of his career providing services in the healthcare sector. Paul graduated from Miami University (Oxford, Ohio), started his professional career as a Practice Administrator for Art of Smiles Dentistry for more than ten  years. During his tenure there, he became a certified EHR trainer for Dentrix, and the practice became a test site for the vendor, providing continual feedback for enhancements and software improvements. Paul guided the practice towards the cutting edge of technological innovations in the field, being one of the first practices nationwide to implement digital x-rays, voice-activated charting & integrated intra-oral photography. He then moved into IT full-time, and earned his Microsoft Certified Systems Engineer (MCSE) certification. He continued to refine his path in IT and healthcare, becoming a Project Manager. Though his projects took him into many fields, including construction, IT infrastructure and automotive support, he continues to be passionate for healthcare. As he was assisting ever-larger healthcare organizations with their project management initiatives, he also earned his Project Management Professional (PMP) certification. His experience led to managing projects for Cincinnati Children’s Hospital and numerous physician practices. Most recently, his healthcare IT expertise was brought to bear when he was hired to manage an enterprise-wide installation of 3M’s CAC/CDIS products for Mercy Health (formerly Catholic Health Partners).