I have had the opportunity to poll my peers at a number of high-profile events and site visits at large integrated delivery systems, renowned academic teaching institutions, health plans, community hospitals, and critical access providers regarding the primary concerns regarding the transition to ICD-10 that are keeping them awake at night.

Rumors regarding another delay, or jumping to ICD-11, began picking up steam during the fall and early winter, and brought back nightmares close to the anniversary of last year’s unprecedented delay. The rumor was quashed by CMS on the heels of letters submitted in February by both HIMSS and AHIMA, strongly urging the agency to maintain the October 1, 2014 implementation date. The agency cited that other industry leaders held the same position regarding the impact of a further delay in the implementation date, and the recognition of the transition as the foundation for the success of many other critical healthcare initiatives.

I sent the CMS response letter to colleagues of mine whose organizations have not moved forward with their ICD-10 planning or whose efforts were derailed a year ago. The majority of my peers who attended HIMSS are moving in the right direction and have at least performed the initial steps of defining their governance structure, developing a charter, assigning the project team, and performing a gap analysis and readiness assessment; however, a number of organizations are stuck with a “pie in the sky” road map at the 10,000-foot level, and after the consultants departed, they are left holding the bag with too few resources to launch the effort. Many senior-level executives assumed their busy directors could add this initiative to their plates and are now scratching their heads when they hear from the stakeholder team that the effort never got off the ground. In response to this issue, I am seeing a trend of organizations now recruiting for a project manager to translate the roadmap to a project plan and facilitate the transition to ICD-10.

Many organizations also are just starting to consider technology solutions to offset the productivity loss attributed to the transition, and many of the CAC vendors are getting extremely busy, and the costs are going up as CAC moves past the proof-of-concept phase to a more mature application offering. The good news is that the products are much more robust and functional, but what if CAC cannot fulfill its promise? Then what—do organizations have the correct number of coders necessary to assure the revenue cycle doesn’t derail?

In addition, many organizations have not done a good job of preparing, carefully planning, and executing their educational strategies. Backfilling and preparing a multifaceted educational plan have not been consistently planned or executed.

Organizations that have done a good job at creating a tactical plan and conducting their remediation tasks are attempting to forecast the “what if” scenarios which could derail their efforts or impact the organization’s ability to get paid timely or accurately. Also, there are some payers who have announced they will not be ready, which will require careful contingency plans for the adversely impacted revenue cycle areas.

“To dual code or not to dual code” is another decision point that needs to be reckoned with at the stakeholder level. Define the purpose, scope, and necessity of this process. Many organizations are taking a targeted approach to lessen the impact on existing resources. Don’t forget to line up resources to backfill for coders who will continue coding in ICD-9-CM.

Last but not least, work with your physicians on an integrated approach to address your critical documentation issues. Take a creative approach to both engage and facilitate training and compliance. Integrate the clinical content remediation as part of your EHR implementation or optimization work. Identify a Physician Champion to be the face of the clinical documentation improvement initiative and the ICD-10 transitional effort.

The following 10-step multifaceted approach is the antidote to counteract the adverse impact of ICD-10 insomnia, consisting of a strong cup of project leadership, a measure of common sense, and a dose of reality:

  1. Project governance
  2. Translate the roadmap into manageable, measurable tasks with clear outcomes and accountabilities
  3. Don’t let the technology drive you
  4. Don’t underestimate workforce factors
  5. Communicate, communicate, communicate
  6. Education: One size does not fit all
  7. Don’t create new problems that don’t exist in your current state
  8. Plan for the unexpected contingency
  9. Try the new workflows on for size (testing)
  10. Celebrate Sweet Success (10/1/14)!

Hopefully, this 10-step approach will provide my peers who are in the thick of their ICD-10 transitional journeys some welcome relief and a good night’s sleep.

About the Author

Cassi Birnbaum, MS, RHIA, FAHIMA, CPHQ, is vice president of health information management for Peak Health Solutions, specializing in providing remote coding, auditing, data collection and analysis, clinical documentation improvement, ICD-10 transition, and HIM resource planning services nationwide. For the last 15 years, Birnbaum was the director of health information and privacy officer at Rady Children’s Hospital in San Diego, Calif.

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