The question, then, is how organizations should proceed at this point. The key lies in continuing to act as though nothing is happening. Even a delay of one or two years would simply give most organizations the time they need to progress to where they should be anyway. For now, continue to meet with your Steering Committee. It would be much easier to adjust your implementation schedule to allow for more time than it would be to have to shorten processes should a delay not happen. With that in mind, here again are the steps you should be taking as you plan your organization’s ICD-10 preparation. If you haven’t yet begun, now is the time to start.
Conduct an Impact Analysis
Before you can hope to be ready for ICD-10, you need to take a look at every part of your organization, to consider what will be changed when the new system is in place. Any department that uses ICD-9 codes will be significantly impacted. More than just IT and HIM, your documentation, labs, pharmacy and other business areas can all be significantly impacted, and working to integrate these areas into the preparedness plan later will be difficult. As you look at the far-reaching effects of the transition, the magnitude of the changes will become clear.
Conduct a Gap Analysis
Along with considering the areas where the code changes will take place, it’s important to evaluate each department in your practice or facility in terms of where it needs to be compared to where it is now. Pay particular attention to areas of risk, and develop action plans to ensure that no area is left unprepared for the implementation.
The documentation your practitioners perform is one of the most critical areas in need of attention as the change to ICD-10 takes place. The level of specificity in ICD-10 compared to ICD-9 is very different, and compliance in this area will make all the difference in reimbursements. The first step here should be to review current practices in light of the new guidelines, to identify areas in which documentation needs to be more specific. Pay particular attention to the new specificity guidelines for the 50 most common diagnoses in your facility.
These reviews form an important part of your overall Clinical Documentation Improvement Plan and should be conducted at least quarterly. Taking a proactive approach in this area is an important investment that will improve your cash flow through reducing claims denied, as well as reducing RAC exposure. Moreover, this is an ideal opportunity to improve the care you give your patients.
Staff Training and Education
One of the most challenging parts of your ICD-10 implementation plan will be getting the training your staff needs in order to ensure that your implementation goes smoothly. Many practitioners feel that ICD-10 is purely a coding issue, but the entire staff will need some form of training to prevent problems. For each member of the staff you will need to consider how much training they need, who will conduct it, when it will happen (this may need to be adjusted based on HHS decisions regarding the potential delay), and finally what form the training will take. There are a variety of options available, from online courses to comprehensive, on-site programs. Carefully consider what will best serve your situation. Of course, pay particular attention to the training for your coders and billing staff, as this will have a direct impact on your future earnings.