ICD-10-CM/PCS Transitin: Planning and Preparatin Checklist by Sue Bwman, RHIA, CCS, and Ann Zeisset, RHIT, CCS, CCS-P Updated May 2014 Editr s nte: This update reflects the change in the cmpliance date frm Octber 1, 2014 t Octber 1, 2015 and replaces the September 2012, March 2011 and June 2007 versins f the ICD-10 Preparatin Checklist. The transitin t ICD-10-CM/PCS (ICD-10) represents much mre than just an increase in cdes and field sizes. The scpe and cmplexity f the transitin are significant and shuld nt be underestimated. Cdes and cded data are much mre widely used than when the US transitined t ICD-9-CM 30 years ag. This transitin will have a pervasive impact thrughut the entire healthcare industry and will be a significant undertaking fr prviders, payers, systems vendrs, and ther stakehlders, requiring rganizatin-wide planning and preparatin. A smth, successful transitin by the cmpliance date f Octber 1, 2015 requires a well-planned and well-managed implementatin prcess. Prper planning and preparatin is critical, s that rganizatins can leverage their ICD-10 investment and mve beynd mere cmpliance t achieve strategic advantage Experience in ther cuntries has shwn that early preparatin is key t success. Als, an early start allws fr resurce allcatin t be spread ver multiple years, rather than incurring a large budgetary investment at ne time. Several f the preparatin activities prvide benefits t the rganizatin befre ICD-10 is implemented, such as clinical dcumentatin imprvement strategies and advancing the knwledge and skills f the cding staff. Organizatins that have planned their ICD-10 implementatin strategy carefully and thrughly, and initiated the planning prcess early, can expect a smther transitin and earlier realizatin f benefits. Early preparatin, adequate educatin, and prper testing may mitigate ptential prblems during the transitin t ICD-10 and will als allw rganizatins t realize the anticipated benefits f ICD-10 sner. These anticipated benefits include: Higher-quality data, which will result in: Imprved ability t measure the quality, efficacy, and safety f patient care Increased sensitivity when refining gruping and reimbursement methdlgies Enhanced ability t cnduct public health surveillance Greater achievement f the anticipated benefits frm electrnic health recrd adptin
2 Imprved efficiencies and lwer administrative csts Increased use f autmated tls t facilitate the cding prcess Decreased claims submissin and claims adjudicatin csts Fewer miscded and rejected claims Decreased need fr manual review f health recrds t meet the infrmatin needs f payers, researchers, and ther data mining purpses Imprved resurce management Reduced labr csts Increased prductivity The ICD-10 implementatin planning and preparatin prcess shuld be accmplished in a phased apprach (quarters refer t calendar year): Phase 1: Implementatin plan develpment and impact assessment (1 st qtr 2009 2 nd qtr 2012) Phase 2: Implementatin preparatin (1 st qtr 2011 2 nd qtr 2015) Phase 3: G live preparatin (1 st qtr 2014 3 rd qtr 2015) Phase 4: Pst-implementatin fllw-up (4 th qtr 2015 4 th qtr 2016) The fllwing planning and preparatin checklist, rganized in phases, was prepared t guide healthcare rganizatins in effectively planning and managing the ICD-10 transitin. This is intended t be a general guide, nt a cmprehensive prject plan. The Phases in the checklist are sequential. Sme steps in the earlier phases are prerequisites t steps in later phases. This means delays in cmpletin f an earlier phase may jepardize the ability t meet the cmpliance deadline. This resurce has been develped t assist all types f facilities in the implementatin f ICD-10-CM/PCS. While this checklist is designed frm the perspective f a cmplex healthcare rganizatin, such as a large acute-care hspital, it can be easily scaled dwn fr any type f smaller rganizatin. The target audiences listed fr each phase are examples f the categries f persnnel primarily affected by the tasks in that phase. The exact jb title r audience may vary slightly depending n the rganizatinal setting, i.e. different rganizatins have different titles. The checklist is nt intended t be an all inclusive list r encmpass every impacted rle in every rganizatin r in a particular rganizatin. They wuld be determined by the rles and respnsibilities f thse individuals invlved in the steps in that specific Phase.
3 The suggested target audiences fr each f the phases are as fllws: Phase 1 Senir executives Health Infrmatin Management (HIM) leadership team Cding staff Clinical dcumentatin imprvement specialists Medical staff Financial management (including accunting and billing persnnel) Infrmatin technlgy (IT) persnnel Clinical department managers Other data users (e.g., quality management, utilizatin management, case management, perfrmance imprvement, tumr registry, trauma registry, research) Business assciates (e.g., systems vendrs, prviders, payers) Phase 2 HIM management persnnel IT persnnel Cding staff Clinical dcumentatin imprvement specialists Medical staff Business assciates Financial management Other data users Phase 3 HIM prfessinals Cding staff Clinical dcumentatin imprvement specialists IT persnnel
4 Business assciates Financial management Other data users Phase 4 HIM managers Cding staff Clinical dcumentatin imprvement specialists IT persnnel Medical staff Financial management Senir executives Other data users Other key stakehlders affected by identified prblems Althugh a suggested timeline fr each phase is indicated abve alng with start and cmpletin dates in the table belw, these dates serve as a general guide. The timeline fr the implementatin plan develpment and impact assessment, implementatin preparatin, and g live preparatin is variable due t a number f factrs, including the type, size, and cmplexity f the rganizatin. Hwever, cmpletin f the impact assessment early is critically imprtant, because withut the impact assessment, an rganizatin cannt reasnably predict the length f time and amunt f resurces required fr the implementatin preparatin and g live phases and therefre can t plan an accurate timeline r budget fr the wrk invlved. Delayed cmpletin f the impact assessment will jepardize an rganizatin s ability t cmplete all ICD-10 implementatin tasks by the cmpliance date, risking claim rejectins and payment delays.
5 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes 3/09-9/10 Establish interdisciplinary steering cmmittee t develp ICD-10 implementatin strategy and versee implementatin prcess (this cmmittee is respnsible fr verseeing all f the steps in the ICD-10 transitin prcess, but may designate ther individuals t cmplete specific tasks). Membership n the Steering Cmmittee shuld include representatives frm the varius business areas impacted by the ICD-10 transitin. At a minimum, representatin shuld include HIM management; HIM cding; senir management; medical staff; financial management; Infrmatin technlgy (IT) Cmmittee chair shuld serve as ICD-10 prject manager thrughut curse f implementatin prcess (HIM backgrund is recmmended) ICD-10 prject manager shuld serve as psitive change agent fr ICD-10 implementatin 10/09 9/10 Frmulate transitin strategies and identify gals. (Steering Cmmittee) Develp rganizatin s ICD-10 implementatin strategy and identify actins, persns respnsible, and deadlines fr the varius tasks required t cmplete the transitin. Develp cmmunicatin plan. Essential first step must be dne prir t beginning the Impact Assessment If an rganizatin chses t have a single steering cmmittee t versee bth the 5010 and ICD-10 prjects, care must be taken t ensure apprpriate stakehlder representatin fr bth prjects, since the stakehlders are nt identical fr bth, and that the cmmittee is able t devte sufficient attentin t bth prjects simultaneusly in rder t stay n track
6 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes Develp a set f clear, cnsistent, and cncise messages cncerning the ICD-10 implementatin prject. (t ensure everyne is speaking with ne vice ) Cnduct regularly scheduled standing meetings f the Steering Cmmittee n a cnsistent basis t ensure cmmunicatin amng key stakehlders. Establish nging cmmunicatin with all affected persnnel. Appint and recgnize external cmmunicatin liaisns t manage cmmunicatin with business assciates and ther external entities. 10/09 1/11 Prvide rganizatin-wide ICD-10 awareness educatin t key stakehlders. Educate senir management, IT persnnel, clinical department managers, and medical staff n the transitin. (Fr suggested target audiences and tpics, see Figure 1. 10/09 10/15 Implement change management strategies t empwer stakehlders t accept and embrace transitin t ICD-10. Steering Cmmittee shuld identify key stakehlders and ensure that awareness educatin is prvided, but designee may prvide the educatin Examples f meetings where this educatin culd be prvided include department managers meetings r medical staff meetings. A special meeting fr certain stakehlder grups, such as senir management and IT, culd be held.
7 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes 1/10 12/11 Assess status f business assciate readiness (e.g., systems vendrs, payers, prviders) Determine vendr readiness and timelines fr upgrading sftware What systems upgrades r replacements are needed t accmmdate ICD-10? What csts are invlved and will upgrades be cvered by existing cntracts? If nt, what will be the prjected cst and when will the cst be incurred? When will upgrades r replacement systems be available fr testing and implementatin? What custmer supprt and training will they prvide? Hw will their prducts/services accmmdate bth ICD-9 and ICD-10 as yu wrk with claims prvided bth befre and after 10/1/15? Hw lng will their prducts accmmdate bth cde sets? Cnsider ICD-10 transitin during cntract renewals (e.g., vendr cntracts, cntracts between payers and prviders) Assess readiness f all rganizatins that receive ICD data Cmmunicate with ther business assciates as t their prgress tward ICD-10 preparedness and when they expect t be ready fr transactin testing. When will payer systems be ready fr testing? 1/10 3/12 Identify key ICD-10 transitin tasks and bjectives. (Steering Cmmittee) Can be dne cncurrently with Impact Assessment (belw), and shuld be cntinually updated during Impact Assessment steps invlving systems inventry and analysis f impact n business prcesses.
8 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes 1/10 3/12 Oversee the develpment f detailed prject plan. (Steering Cmmittee) Develp internal implementatin timeline and specify resurces required t cmplete identified tasks. Articulate all key stakehlders rles and respnsibilities. Delineate transitin tasks, deadlines, and respnsible individual(s). 1/10-3/12 Assess impact f ICD-10 transitin n all rganizatinal peratins (Impact Assessment) Assess rganizatinal readiness fr transitin, including: Identificatin f affected business areas and individuals (medical, clinical, administrative) * Identificatin f affected systems, applicatins, databases Impact n data availability and use Infrmatin exchanges f ICD data between business areas and with external entities Organizatinal capacity (including budget) Current and future rganizatinal plans and acquisitins (e.g., mergers, purchase f physician practices r healthcare facilities) Data gvernance plan Cnduct survey f all business areas t determine level f impact f the transitin. Can be dne cncurrently with Impact Assessment, and bth the timeline resurce identificatin shuld be cntinually updated during Impact Assessment phase. This is nt ne persn r grup, but it culd invlve individual department prject plans, and then merging them int ne master plan. * Identificatin f affected business areas and individuals depends n the systems inventry and business prcess impact assessment. If n data gvernance plan exists, ne shuld be develped.
9 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes Educate IT persnnel n cde set specificatins and pertinent regulatry requirements, including the lgic and hierarchical structure f ICD-10-CM and ICD-10- PCS; cnsider the fllwing: Date-f-service-driven cmpliance date ICD-10-PCS is nly replacing the ICD-9-CM prcedure cdes used fr facility reprting f hspital inpatient services (use f CPT cdes is nt affected) Character-length specificatins Numeric vs. alphanumeric frmat Use f decimals Availability f cdes, descriptins, and applicable supprt dcumentatin and guidelines in machine-readable frm Determine hw lng dual cde sets will need t be maintained. Claims fr services prir t ICD-10 cmpliance date (including claim resubmissins and appeals) Histrical data fr analysis (e.g., research, trending, auditing) Hw will histrical data be managed? Hw many lcatins r applicatins will huse the histrical data? What are the resurce implicatins? Determine wh will have access t this data. Perfrm rganizatin-wide systems audit Inventry all systems applicatins and databases using ICD-9-CM cdes, cnsidering: Hw many systems will be affected and what types f system changes will be made? Identify every applicatin and database that captures, retains, r reprts an ICD-9-CM cde. Identify applicatins that dn t currently capture ICD-9-CM This step wuld be based upn the rganizatins data gvernance plan.
10 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes cdes, but capture f ICD-10 cdes is planned in the future. Dn t frget t identify stand-alne applicatins and databases that are created and managed by individuals r single departments. Is the system develped and maintained in-huse r by an utside vendr? Is an applicatin service prvider used fr any systems applicatins? Fr vendr systems, are they custmized in any way? Are there interfaces between systems? Hw are ICD-9-CM cdes used in each system? Are bth ICD-9-CM diagnsis and prcedure cdes used? Will ICD-10-CM and ICD-10-PCS cdes serve the same purpse and will a change in cde sets impact the results? Where d ICD-9-CM cdes riginate frm? (e.g., entered manually, imprted frm anther system) Are there system interfaces that use ICD-9-CM cdes? Hw is the quality f data checked? Perfrm detailed analysis f systems changes that need t be made (see Figure 2 fr examples f systems and applicatins that may use cded data and therefre wuld need t be mdified). Changes fr cnsideratin include: Field size expansin Alphanumeric cmpsitin Decimal use Redefinitin f cde values and their interpretatin Expanded cde descriptins Edit and lgic changes Table structure mdificatin
11 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes Expansin f flat files cntaining ICD-9-CM diagnsis and prcedure cdes Changes t systems interfaces Changes t data input screens and screen displays Priritize sequence f systems changes and estimate cst; refine previus budgetary estimates as necessary Map electrnic data flw t inventry all reprts that cntain ICD-9-CM cdes. Wh is using these reprts? Are these reprts still needed? D the reprts cntain the infrmatin users need? Are new r mdified reprts needed? Hw lng will bth ICD-9-CM and ICD-10 cde sets need t be supprted? Will system strage capacity need t be increased? Systems vendrs is supprt fr bth ICD-9-CM and ICD-10 cde sets addressed in the cntract? Hw lng is supprt fr bth cde sets anticipated? What kind f supprt is needed? Internal IT systems hw lng will the ICD-9-CM cde set cntinue t be accessible and t whm will it be accessible? Is system strage capacity adequate r will it need t be increased? Identify new r upgraded hardware/sftware requirements Since the ICD-10 cde sets are very amenable t the use f electrnic tls in the cding prcess, and it is expected that the use f technlgy will significantly imprve cding prductivity and accuracy, is cnsideratin being given t replacing the use f hard-cpy cde bks with encding sftware and/r cmputer-assisted cding technlgy? Will hardware upgrades be needed t ensure ptimal system perfrmance? This step shuld be dne in cnjunctin with assessing vendr readiness.
12 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes Will additinal cmputers r larger mnitrs be needed? Build flexibility int IT systems currently under develpment t ensure cmpatibility with ICD-10 and, when pssible, future versins f ICD; ensure that any Requests fr Prpsal fr new systems under cnsider include a requirement fr ICD-10 cmpatibility. Analyze impact n all business prcesses Analyze impact n all peratinal prcesses that currently use ICD-9-CM cdes as well as thse fr which ICD-10-CM r ICD-10-PCS cdes are intended t be used in the future Assess impact n dcumentatin prcesses and wrk flw Evaluate current data flw, wrk flws, and peratinal prcesses t identify thse impacted by the ICD-10 transitin and determine pprtunities fr imprvement Identify reprts and frms requiring mdificatin Identify plicies/prcedures that need t be develped r revised Identify impacted internal and external reprting prcesses (e.g., registries, quality measures, perfrmance measures, state data reprting) Cnduct gap analysis f cding staff knwledge and skills fr ICD-10 envirnment. Assess cding staff knwledge in bimedical sciences (anatmy and physilgy, pathphysilgy), medical terminlgy, and pharmaclgy. Refresh cding staff knwledge as needed based n the assessment results. Cmmunicate with cntract cding services t ensure their cding staff is similarly being prepared t meet the demands f ICD-10 cding and t determine their strategy and timeline fr ensuring their cding staff achieve prfessinal ICD-10 cmpetence. Assess quality f medical recrd dcumentatin
13 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes Evaluate samples f varius types f medical recrds t determine whether dcumentatin supprts level f detail fund in ICD-10. Sampling techniques culd include randm samples; mst frequent diagnses r prcedures; diagnstic r prcedural categries knwn t represent dcumentatin prblems with ICD-9-CM. Implement dcumentatin imprvement strategies t address areas where dcumentatin is fund t be lacking. Cnsider changes in dcumentatin capture prcesses (such as prmpts in electrnic health recrd systems) t facilitate imprvements in dcumentatin practices. Educate medical staff n findings frm dcumentatin review and the dcumentatin elements needed t supprt ICD-10 cdes, thrugh the use f specific examples, and emphasize the value f mre cncise data capture fr high-quality data. Designate a physician champin t assist in medical staff educatin and prmte the psitive aspects f the ICD-10 transitin. Assess impact n cding and billing prductivity Identify ways prcesses and wrk flws culd be imprved. Analyze hw business areas might leverage their use f ICD-10 cdes t imprve effectiveness and efficiency f their peratins. 1/10 6/12 Develp ICD-10 implementatin budget. (Steering Cmmittee r designee) (The amunt f anticipated cst fr the ICD-10 transitin is dependent n the size and cmplexity f the rganizatin, as well as the degree f system integratin, need fr utside technical assistance, and the number f systems, applicatins, and interfaces that need t be updated. The largest budgetary expenses are generally systems upgrades and educatin.) ICD-10 budget must be cntinually updated as a result f infrmatin learned during the Impact Assessment (e.g., training csts cannt be
14 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes Identify all ICD-10 transitin expenses and estimate assciated csts, including: Sftware mdificatins (csts fr in-huse as well as vendr system changes) Educatin (bth cding staff as well as ther persnnel needing educatin) Hardware/sftware upgrades Testing related csts Staff time Temprary r cntract staffing t assist with increased wrk resulting frm the transitin, such as cding/billing backlgs, IT supprt, r cding accuracy review Cnsulting services t assist with transitin Reprt redesign (and develpment f new reprts) Reprinting f paper frms Data cnversin Maintenance f dual cde sets Additinal sftware r ther tls/resurces t facilitate the ICD-10 transitin (such as an electrnic mapping tl) r imprve peratinal prcesses Identify departmental budget(s) respnsible fr each transitin cst, including systems changes, hardware/sftware upgrades, and educatin Estimate the amunt f cntingency and reserve funds required fr the ICD-10 transitin Allcate ICD-10 implementatin csts acrss multiple years Identify ther prjects that will be cmpeting fr resurces (financial, persnnel) during the ICD-10 transitin perid. Update budget estimates as needed after cmpleting ther ICD-10 planning and impact assessment activities determined until the individuals requiring training, the level f training needed, and the timeframe in which the training is needed have been identified).
15 PHASE 1: IMPLEMENTATION PLAN DEVELOPMENT AND IMPACT ASSESSMENT 1 st qtr 2009 2 nd qtr 2012 Recmmended Key ICD-10 Transitin Steps/Milestnes 3/10 6/12 Assess training needs Keep in mind that multiple categries f users f cded data require varying types and levels f ICD-10 educatin and it will be needed at different times (See Figure 3 fr examples f types f data users requiring sme level f ICD-10 educatin). Determine wh needs educatin, what type and level f educatin they need, and when they need educatin. Determine the mst apprpriate and cst-effective methd f prviding ICD-10 educatin t the different categries f individuals (e.g., traditinal face-t-face classrm teaching, audi cnferences, self-directed learning prgrams, web-based instructin (self-directed r instructr-led). Determine whether educatin will be prvided thrugh internal r external mechanisms, r a cmbinatin f bth. AHIMA s rle-based mdels prvide a gd resurce fr identifying a suggested timeline fr ICD-10 educatinal activities fr varius rles and settings. Onging Prvide senir executives and impacted stakehlders with regular updates as t ICD-10 transitin prgress. Training needs cannt be assessed until all affected business areas and individuals have been identified.
16 PHASE 2: IMPLEMENTATION PREPARATION 1 st qtr 2011 2 nd qtr 2015 Recmmended Key ICD-10 Transitin Steps/Milestnes 1/11 12/12 Prvide training n the use f the GEMs and mapping prcesses and technlgy t persnnel wh will be invlved in data cnversin prjects. 1/11 12/12 Determine impact f transitin n lngitudinal data analysis. Will legacy data need t be cnverted? If s, hw will it be cnverted? If cded data will be mapped between ICD-9-CM and ICD-10-CM/PCS using the GEMs, will applicatinspecific mappings need t be develped? Determine which data will be linked using mapping applicatins and which data will be maintained separately accrding t the surce cde set. 1/11 12/12 Prvide educatin t individuals (ther than cding staff) identified during Impact Assessment. Fr example: This phase may verlap with Impact assessment phase, but assciated Impact Assessment tasks must be cmpleted befre specific preparatin steps can be cmpleted (e.g., systems changes can t be made until a systems inventry t identify needed changes has been cmpleted; training can t be prvided until the individuals needing training and the level f training needed have been identified) This culd be prvided internally r externally
17 PHASE 2: IMPLEMENTATION PREPARATION 1 st qtr 2011 2 nd qtr 2015 Recmmended Key ICD-10 Transitin Steps/Milestnes Educate data users n differences in classificatin f diseases and prcedures in ICD- 10, including definitins and cde categry cmpsitin, in rder t assess impact n data trends Educate data users (e.g., case management, utilizatin management, quality management, data analysts) n data cmparability issues and impact n lngitudinal data analysis Educate data users n what the General Equivalence Mappings (GEMs) are and what their rle is in the ICD-10 transitin prcess. 1/11 6/14 Peridically fllw-up n readiness status f business assciates by cntacting them (e.g., payers, prviders, systems vendrs) fr an update n their ICD-10 transitin prgress and any changes t their readiness timeline cmmunicated during Phase 1. 1/11 6/14 Implement systems changes. 1/11 12/14 Payers: Cnvert cverage plicies and prvider cntract template. 1/11 12/14 Cding staff shuld cntinue t increase familiarity with the ICD-10 cde sets and the assciated cding guidelines; educatin n the bimedical sciences and pharmaclgy shuld cntinue t be prvided t cding staff as identified during the knwledge gap analysis. 1/11 3/15 Mdify r develp plicies/prcedures, reprts, and frms identified in Phase 1. 1/11 3/15 Re-engineer prcesses and wrk flws earmarked fr imprvements in Phase 1. 1/11 6/15 Mdify ICD-10 prject plan and timeline as needed. 1/11 6/15 Cntinue t assess quality f medical recrd dcumentatin, implement dcumentatin imprvement strategies as needed, and mnitr impact f dcumentatin imprvement strategies. 4/11 6/15 Mdify ICD-10 budget as needed. 6/11 9/14 Assess ptential reimbursement impact f transitin. Inpatient cders shuld becme familiar with ICD- 10-PCS definitins such as rt peratins and appraches.
18 PHASE 2: IMPLEMENTATION PREPARATION 1 st qtr 2011 2 nd qtr 2015 Recmmended Key ICD-10 Transitin Steps/Milestnes Evaluate ptential DRG shifts. Evaluate changes in case mix index. Cmmunicate with payers n anticipated changes in reimbursement schedules r payment plicies. 6/11 12/14 Develp strategies t minimize transitin prblems and maximize pprtunities fr successful transitin. Assess impact f decreased cding prductivity n rganizatin s accunts receivable status. Hw lng is a decline in cding prductivity expected t last? What steps culd be taken t reduce the impact f decreased cding prductivity? Eliminate cding backlgs prir t ICD-10 implementatin. Use utsurced cding persnnel t assist with wrklad during the initial perid after ICD-10 implementatin. Priritize medical recrds t be cded. Prvide cding staff with adequate ICD-10 educatin and prvide refresher training immediately prir t the cmpliance date t imprve cnfidence levels and minimize a decline in prductivity. Assess medical recrd dcumentatin quality and implement any necessary dcumentatin imprvement strategies prir t ICD-10 implementatin. Emply electrnic tls t supprt the cding prcess. Assess impact f decreased cding accuracy. What is the anticipated impact n cding accuracy? Hw lng is it expected t take fr cding staff t achieve a cmparable level f Implementatin variables that can affect cding prductivity include the amunt and level f preparatin, extent f educatin and credentials, cding experience, knwledge f anatmy and pathphysilgy, extent f ICD-10 training, quality f medical recrd dcumentatin, and rganizatinal size and cmplexity; ICD-10 experience in ther cuntries shwed a prductivity decline f 3-6 mnths
19 PHASE 2: IMPLEMENTATION PREPARATION 1 st qtr 2011 2 nd qtr 2015 Recmmended Key ICD-10 Transitin Steps/Milestnes prficiency t ICD-9-CM? What steps culd be taken t imprve cding accuracy? Assess cding knwledge/skills and prvide apprpriate level f educatin. Clsely mnitr cding accuracy during the initial implementatin perid and prvide additinal educatin as needed. Identify ther ptential prblems r challenges during the transitin and implement strategies aimed at reducing the ptential negative impact. 6/11 3/15 Develp cntingency plan fr cntinuing peratins if critical systems issues r ther prblems ccur when the ICD-10 implementatin ges live. 4/12 1/15 Develp cmmunicatins plan in preparatin fr g-live This plan will utline the steps fr hw t reprt an issue at g-live, wh the pints f cntact will be, hw t disseminate infrmatin/updates t all parties, etc. 4/12 12/14 Prvide early intense training t designated cders and thers invlved in ICD-10 implementatin planning/preparatin prjects (e.g., training, mapping, auditing). 3/13 11/14 Cnduct internal testing and validatin f systems changes. 12/13 3/15 Once systems vendrs, payers, and ther business assciates are ready fr testing, begin external testing. Onging Cntinue t prvide senir executives and impacted stakehlders with regular updates as t ICD-10 transitin prgress.
20 PHASE 3 : GO LIVE PREPARATION 1 st qtr 2014 3 rd qtr 2015 Recmmended Key ICD-10 Transitin Steps/Milestnes 1/14 3/15 Cnfirm with systems vendr(s) that changes/upgrades in vendr systems have been cmpleted. Determine the level f supprt fr g-live. Wh will be the pint f cntact shuld issues arise. 1/14 9/15 Finalize all systems and ther changes nt cmpleted in Phase 2, cmplete testing f systems changes, and prvide intensive ICD-10 educatin t cding staff. 1/14 9/15 Cmplete all in-huse systems changes and testing. 1/14 9/15 Make mdificatins in respnse t the results f systems testing and cnduct regressin testing. 1/14 9/15 Review and test cntingency plan fr cntinuing peratins if critical systems issues r ther prblems ccur when the ICD-10 implementatin ges live. 1/14 9/15 Cmplete external testing. 1/14 9/15 Prvide intensive educatin t cding staff. All cding staff shuld cmplete cmprehensive ICD-10 educatin nt mre than 6-9 mnths prir t the cmpliance date. It is recmmended that training be cnducted by an individual hlding a valid ICD-10 training certificate frm AHIMA t ensure the quality and cnsistency f ICD-10 educatin. Surces f training include: Traditinal classrm training Distance educatin curses Audi r web-based prgrams Self-directed learning using printed materials r electrnic tls Nt all cding staff will require the same type r amunt f ICD-10 educatin. It is estimated that hspital inpatient cding staff will require apprximately 50 hurs f ICD-10 educatin because they will need t learn bth ICD-10-CM and
21 PHASE 3 : GO LIVE PREPARATION 1 st qtr 2014 3 rd qtr 2015 Recmmended Key ICD-10 Transitin Steps/Milestnes ICD-10-PCS. It is estimated that cding staff wrking in any setting ther than the hspital inpatient setting will require apprximately 16 hurs f ICD-10 educatin because they will nly need t be trained n ICD-10-CM and nt ICD-10-PCS. Training fr cding staff wrking fr a physician practice medical specialty area r specialty clinic shuld be fcused n the cde categries mst applicable t the particular patient mix. Test ICD-10 prficiency after training has ccurred and prvide additinal training t address identified areas f weakness. Dcument cmpletin f ICD-10 training in persnnel files. Cmmunicate with cmpanies supplying cntracted cding staff t ensure they have received the necessary educatin and ask fr dcumentatin cnfirming the extent f educatin prvided and the qualificatins f the educatr (e.g., AHIMA training certificate hlder). 1/14 9/15 Cmplete educatin f data users if nt cmpleted in Phase 2. Refer t Figure 3. 1/14 9/15 Cntinue t assess quality f medical recrd dcumentatin, implement dcumentatin imprvement strategies as needed, and mnitr impact f dcumentatin imprvement strategies. 1/14 9/15 Reslve any identified prblems (e.g., testing failures, identificatin f business prcesses r systems applicatins that are impacted by the ICD-10 transitin but were missed during Impact Assessment). 1/14 9/15 Mdify ICD-10 prject plan and timeline as needed. 1/14 9/15 Mdify ICD-10 budget as needed. 1/14 9/15 Cntinue t prvide senir executives and impacted stakehlders with regular updates n ICD-10 prject status. 6/14 9/15 Execute the implementatin cmmunicatin plan
22 PHASE 3 : GO LIVE PREPARATION 1 st qtr 2014 3 rd qtr 2015 Recmmended Key ICD-10 Transitin Steps/Milestnes 9/30/15 Ready t g live with ICD-10-CM/PCS fr dates f service n r after 10/1/15 ICD-10 Milestne: 10/1/15 Claims fr services prvided n r after this date must use ICD-10-CM fr diagnses and acute care hspitals must use ICD-10-PCS fr inpatient prcedures (Nte that there will be n extensin r grace perid nn-cmpliant claims will be rejected and will need t be resubmitted with ICD-10 cdes.)
23 PHASE 4: POST-IMPLEMENTATION FOLLOW-UP 4 th qtr 2015 4 th qtr 2016 Recmmended Key ICD-10 Transitin Steps/Milestnes 10/15 6/16 Mnitr impact n reimbursement, claims denials/rejectins, and cding prductivity and accuracy, identify prblems r errrs, and take steps t address identified prblems/errrs. 10/15 6/16 Steering Cmmittee shuld cntinue t meet regularly t share infrmatin regarding issue identificatin (e.g., high number f claims denials/rejectins, unexpected cding backlgs, lwer-than-expected cding accuracy rate, systems glitches), status f issue reslutin, lessns learned, and best practices identified as part f the ICD-10 implementatin experience. 10/15 6/16 Mnitr systems functinality and crrect errrs r ther identified prblems as quickly as pssible; implement cntingency plan if needed. 10/15 6/16 Mnitr cding accuracy and prductivity and implement strategies t address identified prblems, such as: Need fr additinal educatin n the ICD-10 cde sets, bimedical sciences, pharmaclgy, r medical terminlgy. Need fr additinal effrts t imprve the quality f medical recrd dcumentatin. Need fr additinal cding prfessinals t assist with cding backlgs r reviewing claims denials/rejectins. 10/15 6/16 Train r re-train staff as necessary. Prvide ICD-10 educatin t new staff. Prvide re-training r additinal training as needed t imprve cding prductivity and accuracy. 10/15 6/16 Assess the reimbursement impact f the ICD-10 transitin, mnitr case mix and reimbursement grup (e.g., DRGs, HHRGs) assignment, and prvide educatin t affected staff n reimbursement issues. Wrk clsely with payers t reslve payment issues (e.g., claims denials/rejectins).
24 PHASE 4: POST-IMPLEMENTATION FOLLOW-UP 4 th qtr 2015 4 th qtr 2016 Recmmended Key ICD-10 Transitin Steps/Milestnes Analyze changes in case mix index. Cncurrently review case mix r reimbursement grups and diagnsis/prcedure cde assignments. Analyze shifts in reimbursement grups. Cmmunicate with payers n anticipated changes in reimbursement schedules r payment plicies. Prvide educatin and feedback regarding reimbursement issues t apprpriate persnnel. 10/15 6/16 Reslve pst-implementatin prblems as expeditiusly as pssible. Fllw up prmptly n significant pst-implementatin prblems, such as claims denials/rejectins r cding backlgs. Wrk with ther staff r external entities as apprpriate until identified prblem is reslved. 10/15 12/16 Cntinue t fllw the implementatin cmmunicatin plan Keep key stakehlders infrmed f issue identificatin and reslutin status thrugh regular updates r use f electrnic cmmunicatin tls such as a Web-based issue tracking system that wuld be accessible t all stakehlders. 12/15 12/16 Begin analyzing data t evaluate the impact f implementing ICD-10. Regularly cmmunicate status f utstanding transitin issues t senir executives.
25 Figure 1: High-Level Awareness Educatin Senir Management Clinical Department Managers Medical Staff HIM Managers and Cding Staff Regulatry requirements X X X X Value f new cde sets X X X X Hw ICD-10 fits within ther internal and external initiatives, including electrnic health recrd implementatin and Meaningful Use incentives, health infrmatin exchange, healthcare refrm, value-based purchasing, and quality measurement and imprvement X X X X Preparatin and transitin effects n rganizatinal peratins (e.g., systems changes, prcesses, plicies and prcedures) Impact n cding prductivity and accuracy Budgetary cnsideratins Impact n legacy data and the differences between legacy and new cding systems. Differences between ICD-10-CM and ICD-10-PCS and hw each is used Impact n each particular department and budgetary cnsideratins Impact n dcumentatin practices and the imprtance f a strategy fr dcumentatin imprvement Implementatin plan and hw it can be adapted fr use in their wn practices Impact n individual physicians and their budgetary cnsideratins Key prvisins f final rule Structure, rganizatin, and unique features f ICD-10-CM and ICD-10-PCS; Resurces fr btaining this educatin include, but are nt limited t: Educatinal prgrams (e.g., webinars, audi seminars, cnferences) X X X X X X X X X X X X X X
26 Jurnal f AHIMA, AHIMA s ICD-TEN newsletter, AHIMA s CdeWrite newsletter, ther resurces available n AHIMA s ICD-10 web page (http://www.ahima.rg/icd10/) ICD-10 materials n Centers fr Medicare and Medicaid Services (CMS) and Centers fr Disease Cntrl and Preventin (CDC) web sites AHIMA s ICD-10 Implementatin Cmmunity f Practice AHIMA ICD10 Rle Based Training Mdel (http://www.ahima.rg/icd10/rle.aspx) Figure 2. Examples f Systems and Applicatins that May Use Cded Data Encding sftware Medical recrd abstracting systems Billing systems DRG grupers Electrnic health recrd systems Clinical systems Decisin supprt systems Cmputer-assisted cding applicatins Registratin and scheduling Utilizatin management Quality management Cmputerized Physician Order Entry (CPOE) systems Clinical prtcls Fraud management systems Case mix systems Managed care reprting systems Case management systems Disease management systems Financial systems Prvider prfiling systems Test rdering systems Clinical reminder systems Perfrmance measure systems Medical necessity sftware Aggregate data reprting systems Registries Cmpliance sftware Patient assessment data sets (e.g., MDS, PAI, OASIS)
27 Figure 3. Examples f Categries f Data Users Requiring ICD-10 Educatin Cders Other HIM Clinicians Senir management Infrmatin technlgy Quality management Utilizatin management Accunting Business Office Auditrs and cnsultants Patient access and registratin Other data users Clinical department managers Ancillary departments Data analysts Researchers Epidemilgists Perfrmance imprvement Crprate cmpliance Data quality management Data security Clinical dcumentatin imprvement (CDI) specialists Payer cntract managers and negtiatrs Registry persnnel Authrs: Sue Bwman, RHIA, CCS Ann Zeisset, RHIT, CCS, CCS-P Acknwledgements: Ann Barta, MSA, RHIA June Brnnert, RHIA, CCS, CCS-P Jill Clark, MBA, RHIA Anita Majerwicz, MS, RHIA Mary Stanfill, MBI, RHIA, CCS, CCS-P, FAHIMA Allisn Vila, MBA, RHIA Lu Ann Wiedemann, MS, RHIA, FAHIMA