By now, everyone in the healthcare industry knows ICD-10 will not be implemented October 1, 2014. What no one knows yet is exactly when the new implementation date will be. CMS has not yet weighed in on the passage of H.R. 4302, “Protecting Access to Medicare Act of 2014.”
The bill focused on preventing the government from cutting physician Medicare reimbursement by 24% April 1. It also included this line:
The Secretary of Health and Human Services may not, prior to October 1, 2015, adopt ICD–10 code sets as the standard for code sets under section 1173(c) of the Social Security Act (42 U.S.C. 1320d–2(c)) and section 162.1002 of title 45, Code of Federal Regulations.
“Unfortunately, I’m not sure the delay will have a beneficial impact,” says Cheryl Ericson, MS, RN, CCDS, CDIP, associate director of education for the Association of Clinical Documentation Specialists (ACDIS). “If it does, I think the benefit is for a minority of organizations rather than the majority of them.”
Healthcare organizations will need to spend additional money on training and in some cases retraining staff at a later date when ICD-10-CM/PCS is ultimately adopted.
In the meantime, smaller healthcare facilities, physician groups, and insurers will now have more time to prepare for the ICD-10-CM/PCS conversion. If they're already prepared, they can put greater financial resources into other health IT expenditures, such as electronic health records (EHR), says William E. Haik, MD, FCCP, CDIP, director of DRG Review, Inc., in Fort Walton Beach, Fla.
ICD-10 training
Coders and healthcare organizations in general are left wondering what to do. Should they continue their implementation and training or should they wait?
Since many of the non-surgical documentation issues which are present in ICD-9-CM will persist in ICD-10-CM/PCS, then physician education should continue, Haik says. Organizations should specifically analyze the individual physician’s documentation and use this analysis to help improve the documentation effort, while also involving the coding and clinical documentation improvement (CDI) personnel.
Regarding specific ICD-10-CM/PCS training, focusing on service line leaders, particularly in the surgical subspecialties, should proceed and accelerate during the delay.
“From a coding standpoint, I believe facilities should concentrate on continuing their ICD-10 training efforts in some form or fashion, and not put the training off until 2015,” says Monica Lenahan, CCS, AHIMA-approved ICD-10-CM/PCS trainer, director of coding compliance and education for Centura Health in Englewood, Colo.
Most coders at Centura Health had either completed their ICD-10 training or were almost finished. Coders had also been coding records using ICD-10 and the facility was about to start dual coding.
“We are developing a strategy to ensure that this training is not lost and will carry the coders through to the new compliance date,” Lenahan says.
How willing with others be to continue (or, in some cases, start) learning ICD-10?
“I worry there won’t be an incentive to continue to prepare for future implementation, as the last delay was supposed to be the only one,” Ericson says. This new delay may cause organizations to stop preparation until after the transition to avoid additional wasted expenses. “I hope that organizations will use this extra time to refine their skills and continue to educate providers and the rest of the medical team about the impact of ICD-10-CM/PCS.”
Coders and CDI specialists should accept the delay and strive to retain ICD-10 knowledge and incorporate it into daily work whenever possible, says Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CCDS, director of coding and HIM at HCPro, a division of BLR, in Danvers, Mass.
“Documentation improvement is needed no matter whether the code set is ICD-9 or ICD-10,” McCall says. “I think CDI programs should stay the course and push for better documentation with ICD-10 in mind.”
Benefits of the delay
The delay could also provide more time for end-to-end testing, especially for CMS. The agency originally announced it would not conduct end-to-end testing, but later reversed the decision. CMS is currently slated to conduct limited end-to-end testing with a sample group of providers in late July. That testing date didn’t provide much time for CMS to compile and share results of the testing. Providers also would have had very little time to plan and implement corrective action based on those results.
“CMS could use the additional time to test to ensure it can pay under the ICD-10 code set, but too many organizations have invested so much effort and expense into training their staff that they may be unable to replicate these efforts next year,” Ericson says.
Even if organizations are leery of putting more resources into ICD-10 training, coders and CDI specialists still need to engage physicians to improve documentation.
“We must hold providers accountable for their performance in risk-adjusted outcomes, engaging whoever we can to promote the good message of documentation and coding integrity,” says James S. Kennedy, MD, CCS, CDIP, president of CDIMD – Physician Champions in Smyrna, Tenn. “We still need to get our MS-DRGs, APR-DRGs, and our HCCs [hierarchical condition categories] right if we are to thrive, not just survive, with healthcare reform.”
Start (or continue) updating EHR and query forms. Coders and CDI specialists now have more time to make changes and get physicians used to the changes. Not sure where the physician documentation is falling short? Use the delay to pinpoint the biggest problem areas and address them.
One mistake many organizations made when CMS delayed ICD-10 implementation in 2012 was to stop preparing.
“The delay will simply provide additional time to fine-tune physician, coder, and CDI education to enable a successful transition,” Haik says.
Email your questions to Senior Managing Editor Michelle A. Leppert, CPC, at mleppert@hcpro.com.