Last week I attended the ICD-10 Summit in Baltimore. The atmosphere was energetic, with a myriad of speakers, attendees, and vendors ready to share their experience and expertise related to ICD-10 readiness and implementation. Sessions were well attended and in many cases standing room only, especially surrounding the topic of provider experiences to date. It was apparent that all in attendance fully anticipate ICD-10 to be a reality by October 1, 2014, at the latest. The majority of individuals I spoke to could easily find a silver lining in the additional time provided by a potential year’s delay. They welcomed the additional time so they could determine ICD-10’s financial and operational impact on their organization, plan and implement educational initiatives, and complete vendor testing, to name a few.
Why a year’s delay was proposed was a hot topic of discussion during the summit. We were fortunate to have Denise Buenning from CMS speak on that topic. Ms. Buenning stated that after review of all the comments, the negative impact on patient care was an overriding concern and primarily responsible for the recommended year delay. Other factors impacting the delay were the 5010 transaction set time delay and the need for all industry segments to implement at the same time. Ms. Buenning stated that CMS welcomes all comments, both positive and negative, related to the proposed delay. These comments should be made during the 30-day comment period, as published in the Federal Register on April 17.
What does a potential one-year delay mean for hospitals? CMS has stated all along that the move to ICD-10 will be revenue neutral. What they mean by that is the overall impact to Medicare expenditures will remain revenue neutral. That does not mean the move to ICD-10 will be revenue neutral for all hospitals.
Several speakers discussed how ICD-10 Data Analytics can help hospitals determine specific financial risk areas. Given the potential for an additional year to prepare, hospitals are encouraged to use that time to their advantage and drill down into the specific documentation requirements for identified financial risk areas to determine actual risk.
In some cases the General Equivalence Mappings (GEM) when run through the ICD-10 DRG grouper do not result in the same DRG, which can mean either a reimbursement gain or loss. Once evaluated, if the DRG in ICD-10 results in a lower payment than currently experienced, hospitals should contact CMS identifying their concerns, including current payment, costs, severity of illness (SOI), and risk of mortality (ROM), where appropriate. CMS will likely rely on hospital and payer input of this nature to identify specific variances to further refine ICD-10 Inpatient Prospective Payment System (IPPS).
ICD-10 projects can be conducted by having current claims data run through a GEM mapping tool which can provide a DRG for each case and compare current payment with potential payment under ICD-10. Another option is to set aside time to code cases in ICD-9 and ICD-10 to determine actual reimbursement variances. A few individuals I spoke to indicated that they like the idea of dual coding to determine impact, but stated that it’s difficult to tell where to begin that coding effort. To better focus their efforts, they either conducted or planned to conduct an I-10 Data Analytic project to determine potential risk first, and then focus dual coding efforts on those identified risks, ranked by greatest financial impact first.
In summary, the overwhelming message was to stay the course and use the additional time provided to identify and mitigate financial and operational risks related to ICD-10 implementation.
Focus on solid educational efforts for coders, clinical documentation improvement specialists (CDIS), and the medical community to ensure the additional documentation specificity is being documented prior to the go-live date sometime between October 1, 2013 and October 1, 2014.
About the Author
Barbara Godbey-Miller is Vice President of HIM Client Development at QuadraMed. Previously she was the Director of HIM at Optum, where she secured an international assignment in Palestine for ICD-10 data reporting. She is an active member of the AHIMA, NYHIMA, and CNYHIMA, and has spoken at several state HIM associations on compliance, audit, and data analytics.
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