THE ROAD TO ICD-10: DOES YOUR CHC HAVE AN IMPLEMENTATION STRATEGY IN PLACE?

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1 CPAs & ADVISORS experience perspective // THE ROAD TO ICD-10: DOES YOUR CHC HAVE AN IMPLEMENTATION STRATEGY IN PLACE?

2 AGENDA ICD-10 development Implementation timelines Organizational strategy Project management phases Organization Planning & impact analysis Implementation & go-live Post-implementation monitoring Training needs 2

3 WHAT IS YOUR STRATEGY?

4 CURRENT STATUS LATEST DEADLINE Final Rule CMS-0043-F s/2014/08/04/ /change-tothecompliance-date-for-theinternational-classification-of-diseases- 10th-revision Issued on July 31, 2014 Finalized new deadline of October 1, 2015 No new code updates until October 1, Reference: MLN Matters SE1240 Revised

5 TRANSITIONING FROM ICD-9 TO ICD-10 5

6 THE ONLY DIFFERENCE BETWEEN THE RIGHT WORD AND THE ALMOST RIGHT WORD IS THE DIFFERENCE BETWEEN LIGHTNING AND THE LIGHTNING BUG. ~ MARK TWAIN 6

7 WHY IS ICD-10 NECESSARY? ICD-9 is 30+ years old Technology has changed significantly! No Room for growth Many categories are full Lack of specificity Not sufficiently descriptive Reimbursement & quality issues 7

8 ICD-10 DEVELOPMENT ICD-9-CM codes will not be accepted for services provided on or after October 1, 2015 ICD-9-CM claims for services prior to implementation date will continue to flow through systems for a period of time 8

9 ICD-9 & ICD-10 COMPARISON ICD digits 1 st digit = numeric or alpha (E or V only) All other digits = numeric ICD-10 Up to 7 characters 1 st character = always alpha, except U 2 nd character = always numeric All other characters = combination 9 Source: AAPC

10 ICD-10 EXAMPLE Chronic gout due to renal impairment, left shoulder, without tophus Corresponding ICD-9 code = Only indicates gouty arthropathy 10 Source: AAPC

11 1-TO-1 MAPPING Some ICD-9 codes will map directly to the new ICD-10 codes Source: AAPC 11 Source: AAPC

12 1-TO-3 MAPPING Additional information may be needed to map to possible solutions (e.g., weeks in pregnancy) Source: AAPC 12 Source: AAPC

13 1-TO-16 MAPPING Some require more specificity (e.g., information about cause of poisoning & type of encounter) Source: AAPC 13 Source: AAPC

14 1-TO-2,530 MAPPING Lack of degree of specificity in ICD-9 may result in large volume of options in ICD-10 Source: AAPC 14 Source: AAPC

15 ICD-9 REIMBURSEMENT & QUALITY ISSUES Example diagnosis: Fracture of wrist Patient fractures left wrist A month later, patient fractures right wrist ICD-9 does not identify left versus right requires additional documentation ICD-10-CM describes LEFT versus RIGHT Initial encounter, subsequent encounter Routine healing, delayed healing, nonunion, or malunion 15

16 A DETAILED ICD-10 CODING EXAMPLE ICD-10 CODE ICD-10 CODE DESCRIPTION S52 Fracture of forearm S52.5 Fracture of lower end of radius S52.52 Torus fracture of lower end of radius S Torus fracture of lower end of right radius S52.521A Torus fracture of lower end of right radius, initial encounter for closed fracture

17 EXAMPLE COMPARISON As Sally walked up her driveway, she landed on her left knee, striking her left shoulder. She heard a pop sound in her right foot, which is swollen, bruised & sore to the touch. X-ray of the right foot reveals a fracture of the 5 th metatarsal at the proximal site. Patient was placed in a walking boot & will return in 2 weeks to evaluate the healing process. If there has been no progress then the patient will be scheduled for surgery to place a screw at the fracture site. 17 Source: AAPC ICD-10 Connect enewsletter

18 EXAMPLE COMPARISON, CONT. ICD-9-CM Code: Fracture of metatarsal bone(s) closed E888.8 Other accidental fall E001.0 Activities involving walking, marching and hiking E849.0 Home accidents ICD-10-CM Code: S92.354A = Non-displaced fracture of 5 th metatarsal bone, right foot, initial encounter for closed fracture W18.30XA = Fall on same level, unspecified, initial encounter Y93.01 = Activity, walking, marching and hiking Y = Private driveway to singlefamily (private) house as the place of occurrence of the external cause 18 Source: AAPC ICD-10 Connect enewsletter

19 ICD-10 DEVELOPMENT: WHO & WHERE ICD-10-CM (diagnoses) will be used by all providers in every health care setting ICD-10-PCS (procedures) will be used only for hospital claims for inpatient hospital procedures 19

20 ICD-10 DEVELOPMENT: PARTIAL CODE FREEZE* DATE October 1, 2011 October 1, 2011*- October 1, 2015* ACTIVITY Last regular annual update to both ICD- 9-CM & ICD-10 Limited code updates to both ICD-9-CM and ICD-10 code sets to capture new technology & diseases or conditions October 1, 2015* October 1, 2016* Go-Live with limited code updates to ICD-10 to capture new technology & diseases or conditions Annual update to ICD *Dates are subject to change per CMS regulation revisions, delays, etc.

21 CURRENT STATUS GRACE PERIOD No grace period for implementation ICD-9 codes will not be accepted for services provided on or after October 1, 2015 ICD-10 codes will not be accepted for services prior to October 1, Source: MLN Matters SE1408 Revised

22 ICD-10 IMPLEMENTATION: WHAT S THE WORST THAT CAN HAPPEN? We have lots of time it will probably be delayed again, anyway 22

23 CRITICAL ISSUES TO BE DISCUSSED PRIOR TO IMPLEMENTATION Compliance dates your health center will have to meet Key elements of ICD-10 Expected implementation costs Critical testing & implementation steps to avoid cash flow disruption 23

24 CRITICAL ISSUES TO BE DISCUSSED PRIOR TO IMPLEMENTATION, CONT. Address challenges in: Payer contracting Encounter documentation Staff training Research & benchmarking data Clinical workflow Strategies for working with your vendors & payers 24

25 WHAT CAN YOU DO TO PREPARE NOW? What questions should you ask your health center software vendor? What questions should you ask your health plans? How can you better streamline the implementation process? 25

26 PREPARING NOW Identify & budget for required systems changes Software changes Increased system storage capacity Know if the necessary upgrades are covered by current vendor contracts Identify potential upgrade costs to your organization 26

27 PREPARING NOW, CONT. Determine the preparedness of your vendors, payers & providers If version 4010/5010 & NPI implementations are an indication 27

28 ICD-10 PMS VENDOR QUESTIONS Are you aware of these & other new government regulations? What is your schedule for ICD-10 software upgrades/training? Will you be upgrading MY version of the software? If yes, what will be the cost for this upgrade? If not, what will be the cost for the version of the PMS software that will accommodate ICD-10? Will you be offering any ICD-10 training? 28

29 PMS VENDOR CHECKLIST Vendor(s) identified Profiled with contact information Vendor contracts assessed Release schedule identified Staff training offered Testing (vendors & your own internal assessment) Implementation timeframes Deployment plan All additional "go-live" factors, including support 29

30 EHR VENDOR QUESTIONS What modifications to my EHR must be made in order to accommodate ICD-10? What type of EHR/PMS interface do you offer? Will I require additional hardware to support the software modifications to my software? If yes, what will be required? What will these upgrades cost? Will you provide training to my providers & staff? 30

31 HEALTH PLANS VENDOR QUESTIONS When will you let us know about changes to coverage & payment due to ICD-10? Will you be offering any training or guidance regarding the migration to ICD-10? Will you be utilizing the CMS ICD-10 GEMs/crosswalks? 31

32 WHAT ARE GENERAL EQUIVALENCE MAPPINGS (GEMs)? Crosswalk tool to assist with the conversion of ICD-9- CM codes to ICD-10 codes and back Can be used in converting payment systems, payment & coverage edits, risk adjustment logic, quality measures & a variety of research applications involving trend data 32 Source: CMS

33 WHEN SHOULD YOU USE GEMS? Translating codes or other coded data Converting a system or application containing ICD-9- CM codes Creating a one-to-one applied mapping (crosswalk) between code sets that will be used in an on-going way Studying the differences in meaning between the ICD- 9-CM classification systems & the ICD-10-CM/PCS classification systems 33 Source: CMS

34 TRANSITION TIMELINE ACTION DATE Review documentation for specificity January 1 June 30, 2015 Change all charge capture documents July 1, 2015 Upgrade electronic record to accept ICD-10 Before July 1, 2015 Train physicians & staff on ICD-10 July/August 2015 Start submitting ICD-10 claims No later than September 1, 2015 Go-live for ICD-10 October 1,

35 IMPLICATIONS OF THE ICD-10 TRANSITION Will affect both clinical & administrative functions/staff PMS & EHR software will most likely need to be upgraded or replaced Health Center workflow will need to be re-engineered Clinical documentation will need to be augmented Staff training, including clinicians, will need to be scheduled Testing the ability of software to handle both ICD-9 and ICD-10 simultaneously for some time after October 1,

36 ORGANIZATIONAL STRATEGY Successful strategic planning & project execution requires: Sponsorship from the top Multidisciplinary team Well-developed project plan Communication! Communication! Communication! 36

37 ORGANIZATIONAL STRATEGY Potential cost of poor preparation: Increased claims rejections & denials Increased delays in processing authorizations & reimbursement claims Improper claims payment Coding backlogs Compliance issues Decisions based on inaccurate data 37

38 ORGANIZATIONAL PLAN FOR IMPLEMENTATION ORGANIZE EVALUATE COMMUNICATE ICD-10 ACT ASSESS PLAN 38

39 PHASE 1: PROJECT ORGANIZATION Organize multi-disciplinary steering committee Administration (top-down sponsorship) Finance Medical records IT Patient accounts/business office Health Center site representatives Clinical Management 39

40 PHASE 1: PROJECT ORGANIZATION, CONT. Identify project manager & a cross-functional team Develop action plans with detailed task breakdown Resource needed to implement tasks/plan Timelines, due dates, objectives Responsible parties Financial implications Evaluation & measurement tools Develop meeting schedule 40

41 PHASE 2: PLANNING & IMPACT ANALYSIS Project planning phase = most time consuming, complex Items for consideration in planning System & database inventory Conduct staff awareness education sessions (include physicians) Assess & plan for staff training needs Gap analysis Identify gaps in physician/clinical documentation by concurrent or retrospective internal audits 41

42 PHASE 2: PLANNING & IMPACT ANALYSIS, CONT. Plan project budget Yearly budget needs, including post-implementation Vendor readiness: Timeline & pass-through cost Assess current processes, work flow & data flow Other payers contract implications Database conversions 42

43 PHASE 3: IMPLEMENTATION & GO-LIVE If Phase 2 is conducted well, then Phase 3 should flow smoothly Monitor project plan status; routine reporting Review & manage budget Implement identified changes to IT system design Testing & validation 43

44 PHASE 3: IMPLEMENTATION & GO-LIVE, CONT. Conduct process improvement activities identified in Phase 2 Conduct on-going physician education on documentation Conduct specific detailed training of coding staff Begin 6 to 9 months before go-live Monitor present workflow & keep current! 44

45 TRAINING NEEDS Who? What? When? Organizational awareness Senior management Clinical management Business & support services Medical Staff Documentation improvement Revised processes 45

46 TRAINING NEEDS, CONT. Target educational modules for defined ICD-10 audience segments Tailor to address varying needs over time leading up to implementation date (i.e., overview versus indepth training, depending on individual role & timing): General Expert Maintenance level training needs 46

47 TRAINING NEEDS, CONT. Train-the-Trainer approach Education & outreach Training & education Prudent purchase of educational resources On-line courses Audio seminars Coding conferences Regional meetings National convention Journal articles Trusted sources 47

48 TRAINING NEEDS, CONT. Medical records & coding personnel technical training Familiarity with new system Increase core knowledge of disease processes, medical terminology, anatomy and physiology Certified staff may need to test out to maintain certification (i.e., AAPC) or obtain adequate CEU hours (i.e. AHIMA) Estimated 16 to 50 hours per coder Front end loaded 6 to 9 months prior to go-live date 48

49 2014 AAPC SALARY SURVEY TRENDS 2014 average salary = $50,775 (8.4% increase from prior year) Average salary for those with less than 1 year of experience = $35,048 Average salary for those with 21+ years of experience = $66,153 Based on responses to American Academy of Professional Coders (AAPC) survey Includes credentialed non-credentialed members & 49 Source: AAPC

50 50 Source: 2014 AAPC Health Care Salary Survey

51 PHASE 4: POST IMPLEMENTATION MONITORING & CONTROLS Evaluate the success of implementation, reinforce & fine-tune additional required changes Evaluate software upgrades Review data quality Review KPIs ~ identify root cause of issues Perform on-going internal coding/documentation audits Continue implementation of process improvement opportunities Reinforce physician training Continue coding education as needed 51

52 52 UNFORTUNATELY, THERE IS NO EASY BUTTON!

53 RECAP: BASIC IMPLEMENTATION APPROACH Assess current risks & gaps Develop an implementation team & plan Document decisions Implement Monitor & reassess periodically 53

54 54 PREPARATION

55 QUESTIONS? THANK YOU! FOR MORE INFORMATION // For a complete list of our offices and subsidiaries, visit bkd.com or contact: Name, Credentials // Title //

56 REFERENCES American Medical Association, Current Procedural Terminology (CPT), Professional Edition American Medical Association, Changes An Insider s View American Academy of Professional Coders (AAPC), 2014 Salary Survey 56

57 REFERENCES, CONT. AHA, Engaging Hospital Leaders with ICD-10-CM & ICD-10-PCS Implementation WEDI Alternative ICD-10 Implementation Timeline CMS, National Provider Teleconference Preparing for ICD-10 Implementation in

58 CMS ICD-10 RESOURCES oding/icd10/index.html?redirect =/icd10 CMS Quick Reference: nloads/icd-10quickrefer.pdf 58

59 ICD-10 RESOURCE: AHIMA Practical guidance (free) Putting the ICD-10-CM/ PCS GEMs into Practice ICD-10 Preparation Checklist Role-based implementation models ICD-10 Readiness and Prioritization Tool Books Pocket Guide of ICD-10-CM/PCS ICD-10-CM/PCS Preview Implementing ICD-10-CM in Hospitals Essential Guide to GEMs E-newsletter (free) Articles (many are free) Webinars/Conferences Online courses ICD-10-CM and ICD-10-PCS overview courses Fundamentals of GEMs course Proficiency assessments Academy for ICD-10 Trainers Academy for ICD-10-CM/PCS (3 days) Academy for ICD-10-CM only (1 ½ days) State Health Information Management Association Volunteer educators Low cost education sessions 59

60 RESOURCES AHIMA ICD-10 Preparation Check List AHIMA Transitioning ICD-10-CM/PCS Data Management Processes AHA Executive Briefing: HIPAA Code Set Rule: ICD-10 Implementation. October 2009 AHA Regulatory Advisory: Adoption of ICD-10-CM and ICD- 10-PCS. February 2009 AHA Engaging Hospital Leaders with ICD-10-CM & ICD-10- PCS Implementation. Slide presentation December 2010 HIMSS (Health Information and Management Systems Society), 60

61 RESOURCES AHIMA ICD-10 Preparation Check List AHIMA Transitioning ICD-10-CM/PCS Data Management Processes AHA Executive Briefing: HIPAA Code Set Rule: ICD-10 Implementation. October 2009 AHA Regulatory Advisory: Adoption of ICD-10-CM and ICD- 10-PCS. February 2009 AHA Engaging Hospital Leaders with ICD-10-CM & ICD-10- PCS Implementation. Slide presentation December 2010 American Academy of Professional Coders, 61

62 DISCLAIMER The information contained in this presentation is not intended to cover all situations or all rules & policies. Reimbursement laws, regulations & policies are subject to change. 62

63 COPYRIGHT CPT codes copyright 2015 American Medical Association. All Rights Reserved. CPT is a trademark of the AMA. No fee schedules, basic units, relative values or related listings are included in CPT. The AMA assumes no liability for the data contained herein. Applicable FARS/DFARS Restrictions Apply to Government Use. 63

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