At the end of April, the Workgroup for Electronic Data Interchange (WEDI) and Healthcare Information and Management Systems Society (HIMSS) convened an “Emergency ICD-10 Summit” aimed at addressing the ICD-10 delay and its implications. The primary goal of the meeting was to develop a road map for the industry that offers clear guidance on implementing the code set moving forward.
The summit brought together payers, vendors, consultants, professional associations, and government agencies to share ideas and engage in productive dialogue about the delay and next steps. Out of these discussions, several key themes emerged:
One concern meeting attendees repeatedly raised was the lack of universal buy-in and support for ICD-10. It was suggested that industry leaders better engage those groups who have historically been opposed to the new code set, such as physicians and provider associations. The provider community’s absence from the summit highlighted the gap that exists between stakeholders. Participants acknowledged that they must bridge this gap in order to successfully move forward with ICD-10.
The group discussed the need to change ICD-10 messaging to make compliance more approachable for providers. In particular, they determined the messaging should focus on the benefits of the new code set and give provider-specific examples, quantifying the advantages where possible. Additionally, they focused on how the messaging should address the credibility of ICD-10 and dispel some common myths. For instance, one member advised providing clarity about “external cause codes,” communicating that those codes exist in ICD-9 without overly impacting current reimbursement, and it is not anticipated that they will cause additional problems in the future.
The idea of fostering confidence in the implementation date was also brought up, and leaders suggested organizations contact their congressional representatives regarding the value of ICD-10 and the consequences of repeated delays. Group members agreed that quantifying the losses incurred thus far would help underscore the importance of setting a firm deadline.
With the lack of stakeholder readiness (i.e. payers, providers and vendors) being a chief reason for the last few ICD-10 delays, the workgroup discussed this topic at length, stressing that organizations should have a firm plan to follow with a set structure to meet a new compliance deadline. More specifically, attendees debated the possibility of setting mandatory milestones or suggested time frames for completing certain critical implementation elements. A key leader emphasized that the Centers for Medicare and Medicaid Services (CMS) need to get involved in setting these milestones and driving the various players to readiness.
Collaborating on Training Efforts
Given the compliance deadline delay, the discussion around training at this time was around clinical documentation improvement. Although many organizations have started training for ICD-10, summit participants saw value in compiling already developed training resources and making them available to all stakeholders, particularly small and medium physician practices that do not currently have these on hand. Several of us in attendance agreed that there is a great need for provider training to be championed and, to some extent, led by providers. However, attendees also pointed out the importance of maintaining brevity in these training sessions so as to be mindful of staff members’ time restraints.
Sharing Testing Results
Testing was another significant conversation topic. Across the board, attendees said that CMS needs to start testing and sharing outcomes industry-wide. Ideally, this should be completed by January 2015, regardless of the new deadline. One member proposed that the Regional Extension Centers (RECs) complete the testing.
Regarding consumer payer testing, one payer at the summit offered to explore the possibility of making its testing results publicly available in a standard way, allowing providers and other stakeholders to see the results and lessons learned.
Considering a Phased Approach
Meeting participants spent considerable time talking about how best to navigate ICD-10 implementation, discussing the idea of a staged or phased approach versus a single date cutover or voluntary adoption. One leader suggested employing contingency plans, such as dual coding, for those organizations that are not ready at the time of a switchover or are having trouble reaching defined pre-implementation benchmarks. It was generally agreed that dual coding could be highly disruptive and have a significant financial impact on the industry, although consensus was not fully reached on this point. The group did agree that they must find better ways to identify those who are not ready for or are struggling with implementation and proactively address their needs.
More Work to Be Done
Although meeting members worked for hours to determine a road map for ICD-10 implementation, at the end of the day, there was a strong sentiment that summit participants must get further commitments from CMS on critical pieces of the process before a road map can be developed. According to WEDI, “The industry is still searching for the most effective methods to complete ICD-10 testing and implementation. Much work remains to gain support from all stakeholders and to convince the industry that there will be a definite compliance deadline.”
Angela Hickman is a senior consultant at Culbert Healthcare Solutions, a professional services firm serving healthcare organizations in the areas of operations management, revenue cycle, clinical transformation and information technology.