Twice in recent weeks, legislation regarding the transition to the ICD-10 coding set has been introduced into the U.S. House of Representatives. One proposed bill would potentially “prohibit the Secretary of Health and Human Services from replacing ICD-9 with ICD-10,” while the latest one is less drastic, and pushes for a required ICD-10 transition period following implementation on Oct. 1, 2015.
It remains to be seen if either of these bills will gain any traction, and generally speaking, there seems to be mixed reactions from industry stakeholders and the medical community on the value of ICD-10. Recently, an exclusive survey done by Healthcare Informatics, in conjunction with QuantiaMD, a Waltham, Mass.-based social network for physicians, found that doctors—many of whom have come out against ICD-10—are not backing down in their distaste for the mandate.
However, according to members of the Washington, D.C.-based consulting firm The Advisory Board Company, it’s time for the transition to finally happen. Specifically, Piper Su, vice president of The Advisory Board Company’s health policy division, says in regards to the proposed bills, “While a few members of Congress continue to voice concerns about the health system’s readiness for ICD-10, what we see this year is more widespread consensus amongst policymakers that the time has come to move forward. The previous delays, combined with early results from end-to-end testing, alleviated some concerns that providers have not been given enough time to comply and are not ready to meet the deadline,” Su says. “Lawmakers are now coming to conclude that no amount of time will yield a perfect transition, so Oct. 1, 2015 may be a fair date for moving forward. However, we expect concerns about the transition to continue, so we also anticipate that there will continue to be close scrutiny as we get closer to that date,” she adds.
What’s more, Ed Hock, managing director at The Advisory Board Company, says that the ICD-10 transition will benefit healthcare providers and patients and that another delay isn’t in the best interests of anyone. Hock says that providers need to prioritize efforts over the next few months to reduce risk. During his time as managing director at The Advisory Board Company, Hock has worked with more than 100 hospitals and health systems specifically on their transition to ICD-10, and focuses mainly on such provider organizations. He recently spoke with HCI Associate Editor Rajiv Leventhal about the industry’s current level of readiness for ICD-10, best strategies to reduce risk, and a key point that provider organizations are overlooking regarding implementation. Below are excerpts of that interview.
How would you rate the industry’s readiness for ICD-10?
Most of the industry is well on the path to readiness. We have seen that the amount of time has been a huge blessing to many providers, and we are also seeing providers—in the last 60 days especially—really accelerate their preparation once we got past the Sustainable Growth Rate (SGR) fix. That’s when things kicked into overdrive across the country. Now is the time for additional end-to-end testing, and the exchanges of data files will prove out if what we’re seeing is really the case. We’re just starting to see that play out though. Overall, [providers] are on a good path.
Is the level of testing that’s going on right now thorough enough?
The level of testing varies widely from provider to provider. I was sitting with a dozen CFOs yesterday, and some of them in the room have tested thousands of files from a double coding perspective as well as exchanging with their payers. Overall, most were pleased with the results, but there is still interesting learning occurring. One provider said they were getting higher rates than they expected, positive results with payers, and all claims were going through. They realized some of the claims were going through ‘too smoothly,’ if you will. So that’s the type of learning we will uncover as we get closer. Not just can you exchange claims, but are claims going to get denied that should or shouldn’t be? How will the real dynamics of coding and revenue cycle play out?
So how do you see this playing out?
Of course there will be some trouble; we feel the well prepared organizations will minimize most of that trouble. There are a number of things that can go wrong from the policy being adjudicated incorrectly or misunderstood, or coders not fully understanding all of the guidelines, or physicians not knowing all the documentation rules they need to follow. So even organizations that have their systems tested should look beyond that to ask themselves, ‘Are all my people who touch ICD-10 codes trained? Have we practiced, and made sure the work product that comes out of those tasks is acceptable as well?’
With dual coding, so many organizations say they are starting to dual code or already have, but the much more interesting questions are the second and third level questions on those dual claims. What type of reimbursement impact are you seeing, or what type of denial rates would you expect on those claims? Either those answers aren’t satisfactory or many providers haven’t yet asked those questions—they are still in the ‘figuring out’ period.