Industry stakeholders weigh in on ICD-10 delay

When Congress passed the Protecting Access to Medicare Act of 2014, it mandated at least a one-year delay in ICD-10 implementation. Members of the Briefings on Coding Compliance Strategies editorial board, who represent a wide range of industry stakeholders, offered their thoughts on two questions related to the delay.

 

Lori Belanger, RN, BSN, RHIT, inpatient coder and CDI specialist at Northern Maine Medical Center in Fort Kent: The delay has both positive and negative consequences to it in regards to the healthcare industry. For those facilities who were on board with the upcoming change, it means an added expense prior to the actual implementation of the new program. For those facilities who were not on board with the change, this allows them the time to catch up. One drawback is a comment I recently heard. The comment had to do with the increased documentation push on the medical staff: "Now that ICD-10 has been delayed, they don't have to be as intense with learning and implementing the documentation changes." From a CDI specialist viewpoint, it is discouraging. We were finally getting the physicians to understand the importance of documentation specification, and now this. In my opinion, this should be the time span the physicians use wisely in learning the documentation specifications needed in the future and not continue to procrastinate. I can say that as a CDI specialist, this extra time will be used in attempts to strengthen the documentation now prior to the eventual changeover.

 

Paul Belton, vice president of corporate compliance for Sharp HealthCare in San Diego: We all need to capitalize on the opportunity to improve in what we are doing now, but doing it even better. The industry needs to analyze what components of their ICD-10 implementation programs should be delayed and what goes forward. It also means a transformation or a shift to enhance and perfect the electronic medical record, clinical documentation, query management, coding as a whole, and education. The delay will afford the industry the opportunity to enhance computer-assisted coding (CAC) systems and denial management while refining communication between all affected parties, particularly physicians, HIM coders, and CDI specialists.

 

Gloryanne Bryant, RHIA, CDIP, CCS, CCDS, HIM professional with more than 30 years of experience in Fremont, California: In general, I believe it means more cost due to an extension. Many organizations were not planning on ICD-10 implementation or education and training expenses in 2015. As a recent survey reported, the hospital portion of the healthcare industry was 95% confident they would be ready by the 2014 date. Many organizations small and large have started or had nearly completed their ICD-10 code set education and training. There will need to be educational refreshing into 2015 and certainly in the months just prior to go live. This also means we need to ensure that HIM coding and CDI professionals have the amount of time they need to practice and study the codes and the necessary documentation. This means our smaller physician practices have yet another year to prepare and use the tools and resources being provided, especially those available at no cost to the practice. But most of all, this means the fight is not over to get ICD-10 live in our healthcare system. There are special interest groups that are still opposed to ICD-10, so that also needs to be addressed. It is disappointing, to say the least, that this happened, but those of us who believe in and are dedicated to the advancement of quality data for quality healthcare will continue to work to achieve having ICD-10 as our national code set. 

 

William E. Haik, MD, FCCP, CDIP, director of DRG Review, Inc., in Fort Walton Beach, Fla.: Obviously, much of the cost of preparing for ICD-10-CM/PCS will be wasted, as there will be a need for reeducation at a later date, or some level of continued education in the presumption ICD-10-CM/PCS will ultimately be adopted.

 

In the meantime, smaller healthcare facilities, physician groups, and insurers will now have time to prepare for the ICD-10-CM/PCS conversion. If already prepared, they can put greater financial resources into other health IT expenditures, such as electronic health records.

 

Additionally, to ensure clinical congruence with the code sets and provide physician buy-in and ownership of the transition, I believe it would be wise for the Cooperating Parties of the Editorial Advisory Board of AHA's Coding Clinic for ICD-9-CM to recruit an equal number of physicians (representing different service lines) to be equal voting members of the Cooperating Parties.

 

Monica Lenahan, CCS, AHIMA-approved ICD-10-CM/PCS trainer, director of coding compliance and education for Centura Health in Englewood, Colorado: The delay means extreme disappointment and loss of trust in the process of implementing ICD-10, not to mention so much time and so many dollars spent and potentially lost. During implementation of our ICD-10 plan, we always had the issue of trying to convince folks that the compliance date was REAL and there would be no further delays. Prior to this latest delay, there was always resistance and the belief that yet another delay would happen. This latest delay reinforces the naysayers. It will be a huge challenge to gain organizational buy-in yet another time.

 

Belanger: From the CDI standpoint, facilities should be taking a closer look at their top 10 diagnoses for each area of specialty. Take the time now to fully expand each diagnosis to its fullest capacity for an understanding of what is required. Continue with the education of staff and possibly expand the education to other groups of individuals who will be affected by this change. They should also be looking at their plans and expand on the areas that were skipped or only skimmed due to time constraints. This extra time will allow for a very strong educational foundation for the new program to be implemented, as opposed to the weaker, cracked foundation that caused these setbacks.

 

Belton: Regardless of the delay, we still have a significant amount of work to perform in regards to achieving appropriate and accurate documentation. Facilities don't need to stagnate. What we need to do is reenergize our commitment to accurate documentation and continue to focus on mitigating risk. Facilities need to ensure they are achieving accuracy with ICD-9-CM. With all the external regulatory reviews and audits performed by the Recovery Auditors, MACs, and ZPICs, facilities need to address denials and reviews. The large amount of Recovery Auditor and MAC "take-backs" prove this. National recovery rates from the external regulatory agencies mentioned above prove we have opportunities right in front of us.

 

Second, we need to understand conceptually that a lot of ICD-9-CM gets carried into ICD-10-CM; so often we have only looked at the differences and forget what can be carried over. In other words, perfection of ICD-9 concepts needs to be capitalized upon. Moreover, facilities need to continue to focus on the following: fewer denials based on medical necessity, the financial impact for value-based purchasing, accountable care organizations and other quality-driven incentives, improved clinical outcomes with patient related risk factors, treatment effectiveness, quality of care rendered metrics, resource intensity based on severity of illness, risk of mortality, and risk of complications. Finally, enhanced documentation does not have to be restricted to ICD-10 implementation. Facilities need to perfect their CDI programs and continue to dual code to continue to perfect coding skills, albeit in a slower fashion. In so doing, facilities should aim for a "seamless" transition into ICD-10 when the final date is solidified.

 

Haik: Since many of the nonsurgical documentation issues that are present in ICD-9-CM will persist in ICD-10-CM/PCS, then physician education should continue. Analyze the individual physician's documentation and use this analysis to help improve the documentation effort, while also involving the coding and 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. 

 

James S. Kennedy, MD, CCS, CDIP, president of CDIMD - Physician Champions in Smyrna, Tennessee: First, I think that facilities and coders should not get stuck in self-pity or play the victim role with this setback, but instead recognize the good that has come out of the ICD-10 exercise. Let's not forget that the Patient Protection and Affordable Care Act (PPACA) can still use ICD-9-CM codes to measure physician and facility outcomes; thus, we must program our EMR systems to capture disease and procedure specificity in a proactive, systematic way. 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.

 

We still need to get our MS-DRGs, APR-DRGs, and our hierarchical condition categories right if we are to thrive, not just survive, with healthcare reform. Don't forget that the PPACA stipulates that the Secretary shall announce a plan for inpatient bundled payments by January 1, 2016. I personally think that the AHA or AHIMA should be more proactive in engaging physicians in the management of ICD-10 by advocating that they be a fifth Cooperating Party, not just settle for them to having a vote on the Coding Clinic Editorial Advisory Board, where they are outnumbered by a 2-to-1 ratio by nonphysicians.

 

Lenahan: 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. For Centura Health, a majority of our coders had completed or nearly completed their formalized ICD-10 training, coded many sample claims in ICD-10, and were ready to embark on 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.

 

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, Massachusetts: It will be important to not lose their investment in any education already done for employees. I do think those learning ICD-10-CM find that it is very similar to ICD-9-CM and will be able to retain what they learned. But ICD-10-PCS is very different and will require continued practice/exposure between now and implementation. Keep ICD-10 as a continued focus, with quarterly refreshers at a bare minimum. I know it is hard trying to dual code. Budget time to practice can be cumbersome for most coding departments. Documentation improvement is needed no matter whether the code set is ICD-9 or ICD-10. I think CDI programs should stay the course and push for better documentation with ICD-10 in mind (even if it does get pushed back again). Many of the code enhancements may not affect which ICD-9-CM code is assigned, but will for ICD-10, so my thoughts are you won't get penalized for over-documenting. Coders/CDI need to accept the delay, and if they have learned basic ICD-10, strive to retain the knowledge and incorporate it into daily work whenever possible.