It’s easy to forget now that there was a time not too long ago when people around the world were working feverishly against a ticking clock as “Y2K” approached.

We dealt with many of the same issues other types of companies dealt with: resource depletion, software vendors, lack of product upgrades, etc. Some of this forced many companies to perform a full install of new software rather than relying on an upgrade, as in some verticals training and process changes still were taking place. Sound familiar?

At the time I was working with one of the top three enterprise resource planning (ERP) software vendors in the field of health and life sciences. I was working in Europe, so I had a global view of the events that were transpiring.

While there are some similarities, there are major differences between Y2K and the transition to ICD-10. Similar to the events the world faced as it moved into the new millennium, the healthcare industry is faced with jumping the chasm into an evolving healthcare ecosystem, with ICD-10 coding and standards serving as the foundation for much of the change!

As with Y2K, the industry has innovators (i.e. many of the mega-health plans and early adopters working towards transition). The industry also has late adopters: providers that have been slower to embrace the challenges and potential opportunities of ICD-10, but in fact are working through the steps toward transition. Both groups are expected to achieve a successful transition to ICD-10 by the compliance date of Oct. 1, 2014. The late adopters pose a small degree of risk to the industry at large and its ability to meet the deadline. However, what I like to call the “laggards” pose a far greater risk.

We need to define “laggards,” and it’s not difficult: Individuals fitting this description often are the last to adopt innovation and typically have an aversion to change. Laggards tend to be focused on more traditional ways of doing business. Laggards often will not move toward change until many others have accepted the change or there is clearly demonstrated value, and they frequently have financial and resource operational constraints as well, which prevent them from embracing and or implementing regulatory change. As the graphic reflects, they make up a small but important segment of the model in this graph:

So, who are the laggards within the industry who are slow or resistant to change, and how do we help them “jump the chasm?”

In many industry surveys we see that some providers have been identified as slow to embrace and begin ICD-10 transitional change, and often there is an assumption that these are small and or rural hospitals and/or physician practices. But do we really know who is in this group, and who responds as merely a “provider” to the surveys being performed across the industry? We need to define this population more thoroughly, and we can do this by looking within our trading community. Could they be critical access hospitals, which still do everything on paper, including clinical documentation and transfers? Are they high-volume, long-term care facilities, or physical therapy providers, whose clinical notes are integral components of their overall treatment plans and contain documentation that will support the ICD codes that will trigger claims and payment?

A major consideration involves thinking outside of the larger, metropolitan areas. Consider the fact that there are more than 20 million people who have access to healthcare in rural settings.  This includes community-based health centers, migrant health centers, church- and charity-based healthcare providers, etc., all of which have a role to play in the industry’s ICD-10 transition. While some of the care these entities provide will be free care, the data that will need to be extracted for reporting, studies and research all will need to be able to be translated into ICD-10 standards to ensure clinical integrity.

Consider the following, which was featured in a January 2013 congressional research report:

Most Americans enter the healthcare system through their local physician’s office, which is the setting for 84 percent of primary care visits. Historically, physicians have operated in what the American Medical Association and others have called a “cottage industry” of small or solo practices around the country. Even now, the majority of the approximately 972,376 doctors and residents in the United States work mainly from smaller, office-based practices. This decentralized network has served to deliver medical services to most Americans, but it has also been cited by analysts as a reason that the healthcare market is inefficient, with patients seeing duplicate providers who may prescribe overlapping treatments or deliver widely divergent, uncoordinated care.



The same report also states that although physician payments account for about 20 percent of medical spending, studies suggest that physicians direct as much as 90 percent of total healthcare spending through referrals, tests, hospital admissions, and other actions.

So if we consider this congressional study, we need to accept that the laggards in the ICD-10 transition are primarily providers – and we also need to embrace the reality as to the risk they place threatening industry-wide compliance as of Oct 2014. We cannot assume that laggards have an intentional aversion to compliance; on the contrary, there are many issues that are cause for concern, including:

  • Lack of vendor readiness. Vendors tend to listen to their high-visibility and/or largest clients. But we also need to look at the smaller, lower-value clients.
  • Many providers also may use a local practice management company that also is being faced with some of the same vendor issues.
  • The industry historically has embraced legacy, homegrown IT applications and/or “off the shelf” applications to run their businesses, especially small-to-mid-size hospitals that traditionally have not been able to afford some of the enterprise-type software available in the market. We also know that, unlike in other industries that have enterprise-wide applications, healthcare has been slow to develop fully integrated enterprise software.
  • A high turnover rate of physician administrative office staff places a great importance on operational efficiency. A recent report by MGMA states that this turnover rate is between 12 to 16 percent, so anything over 20 percent needs to be addressed. Understanding that the claim starts at the point of care, one needs to consider the implications this turnover can have as it pertains to the change trends currently affecting the industry
  • Awareness, education and training usually are not big considerations among most small providers, but these arenas will become critical for ICD-10 compliance, as process changes are inevitable to some degree.
  • “Cause no harm” providers historically have worked for the good health of a certain population, but they have struggled with the many phases of managed care, as it could tend to seem like it was an obstruction to being able to do what they felt was the right thing to do for their patients. So, what is the value for a practicing physician, or a critical access hospital, or a migrant health clinic/community support health clinic? Such populations tend to be risk-heavy, but how do we mitigate the risk? What is the value of this ICD-10 system, and have we communicated it to them effectively?

I certainly don’t have all the answers to resolve all these issues, but I do know we can take a look at Y2K and take a few pages from it. We can mitigate risk by building business continuity strategies within our trading partner communities. We should establish a triage-like system for identification of challenges for this group, classifying business problems and/or risk in the following groups:

  • Catastrophic: fatal to business
  • Critical: significant loss of business function and economic loss
  • Major: economic loss only
  • Minor: economic loss only

We should share lessons learned and approaches from across the trading partner community as we review each grouping.

Once this process is completed it will facilitate the mitigation of issues and avoidance strategies, providing a “move-forward roadmap,” and it will provide some support for the provider segment that meets the definition of “laggard” on the innovation model.

We also need to further develop knowledge management strategies with affinity or knowledge communities, again within our trading partner communities. We can establish governance for collaborative decision-making. We can build a public relations effort, too, which can support organizational learning.

It is important to look across the Industry for resources that can facilitate the effort to move providers forward, and it is my recommendation that we look first to collaboration: specifically, be sure to share services and resources and support among trading partners. I also believe it is time for the industry associations to step up and provide some resources to their memberships, and it is my point of view that the regional extension centers also need to play an integral role in moving the late adopters and laggards along. After all, without a successful ICD-10 transition, the industry will struggle to achieve meaningful use in its second and third iterations, and/or interoperability – and this will make it difficult to manage quality of care and costs.

About the Author

Ellen VanBuskirk, senior principal in business consulting for Infosys Public Services, is a healthcare consultant focused on compliance strategies with a mission to work across the Healthcare value stream to meet regulatory challenges. VanBuskirk has conducted business development efforts in support of healthcare compliance and reform, as well as ICD-10 transformation by both provider & payer organizations. With more than 20 years of success in leading business teams and identifying emerging opportunities and challenges in the healthcare industry, VanBuskirk brings deep expertise in health plan regulatory and compliance initiatives, including healthcare reform, ICD-10 transformation, meaningful use, HITECH and HIE.

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