Developing an ICD-10 project plan for complying with the October 2014 deadline is one important first step many organizations have accomplished.
While there are some great resources for organizations to utilize in order to manage key remediation components involving assessment and implementation, many organizations are relying on a “check-the-box” methodology for mitigating risks associated with the conversion to ICD-10. While this is a good framework for managing the global tasks associated with ICD-10, this approach will not provide an organization with the content expertise required for this high-risk, enterprise-wide initiative. While many organizations have many talented resources, the average organization’s resources are stretched so thin, it just does not have the bandwidth of personnel to manage all of the activities required to prepare while maintaining current operations.
Managing a multi-year, enterprise-wide initiative is a monumental task requiring planning, preparation, collaboration, progress evaluations and alternative decisions made throughout the life cycle of the project. With any multi-year enterprise project, how do organizations measure year-by-year efficiency gains? How do you deal with attrition to ensure that loss of staff resources at any given stage does not negatively impact project outcomes?
Simple Solution on a Project Plan
For example, consider that there is an industry-wide shortage of medical record coders. The simple answer to meet the demands of the industry would be to train more coders. This might be a viable solution for the productivity issues associated with ICD-10, but how many CFOs would be comfortable with entry-level coders determining their organizations’ reimbursement? How well do you think compliance officers would sleep, knowing the risk to their organization if it proves to be dependent on entry-level coders?
The process of coding is more complex than simply assigning a code from a coding book – it takes years of education, training and mentoring in order to become a seasoned coding veteran. You may have met the goal of providing staff education and training, but do you have confidence that, after the coders and physicians are educated, they will achieve the same level of proficiency they exhibited with the ICD-9 system?
Managing the requirements of clinical documentation specificity and coding quality is a continuous process that will require dedicated resources focused on documentation improvement, operational process improvement and financial analysis to ensure receipt of appropriate reimbursement.
Clinical documentation and coding quality complexities long have existed within the ICD-9 coding system. To manage this process effectively requires technical resources collaborating together with the common goal of appropriately documenting the patient story, which in turn is used for reimbursement, compliance, quality measures, etc. Professionals who specialize in these areas – including clinical documentation specialists, coders, auditors and finance staff – all understand the complexities associated with this process.
There also are technology solutions being developed every day, and we are in the beginning of a genuine transformation. But this costs money, even if it’s money well spent, and that’s something of which organizations do not always have a surplus.
What Really Matters?
What really matters? Not necessarily that the implementation activities simply get done, or checked off the list. What really matters is that the implementation activities get done right, and that you have a mechanism with which to measure the effectiveness of those efforts. Waiting until after October 2014 to determine whether the education provided to coders and physicians was adequate, or whether the IT system testing conducted could have been more robust, when your cash flow is being disrupted due to failed claims – that is not a good strategy.
So be sure to use a checklist to measure outcomes.
About the Author
John Pitsikoulis, RHIA, serves as a strategic advisory services client executive and ICD-10 practice leader at CTG Health Solutions. He has more than 25 years of health information management, coding, compliance and hospital revenue cycle consulting experience. His experience includes working with clients on RAC engagements, hospital performance improvement initiatives, case mix index analyses, revenue cycle performance improvements, clinical documentation improvements, coding quality infrastructure implementations and charge capture engagements. He also has directed numerous national engagements involving clinical management and litigation advisory assistance.
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