It is finally here—the day we have all been waiting for—the official implementation date for ICD-10. Actually there still are approximately 30 days to go, but we are clearly in the final stretch and, at this point, the mission should be to ascertain that the “t’s” have been crossed and the “i’s” dotted for the most critical items.
Three key areas should be examined to ensure they have been adequately addressed in preparation for the big launch date of October 1, 2015: Readiness, impact analyses and monitoring/feedback mechanisms.
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At this late date everyone and everything within the organization should be ready for the go-live date. But rather than make that an assumption, it is important that true assessments be performed to ensure that this is indeed the case.
Internal Staff. If your organization does its own coding and billing then you must assess the current proficiency and skill levels for any individuals who will be impacted by the new code set. Has your staff received detailed training to prepare them to assign all of the necessary ICD-10-CM codes with accuracy and efficiency?
If not, where are your gaps and what are you doing to quickly fill those gaps? What type of assessment have they taken to show their proficiency? If you have not tangibly measured their proficiency you should do that as soon as possible so you know their areas of strengths and opportunities for improvement.
What type of ongoing support is available for your staff? Any new skill requires practice, and ongoing feedback and support, so it is important that you ensure that this support is available to your staff either through internal or external mechanisms.
If you find that there are staff members that need additional training prior to the implementation, do not delay getting this accomplished. There are a variety of training options available to address ICD-10 preparedness; avail yourself of these options so that you are as prepared as possible.
Payors. Most payors began testing with individual providers and clearinghouses in early 2015. If you did not participate in this electronic testing, how do you know that you will be able to successfully submit claims on the go live date? In addition to claim submissions, it is important to know how your payors are actually going to process the claims differently. Besides the obvious fact of new diagnosis codes, is more specificity required? Will the payors accept unspecified codes? Are there specific medical conditions that you are being paid for today that will be denied in an ICD-10 world?
Medicare has published a list of proposed “future” Local Coverage Determinations (LCDs) converted to ICD-10 that is available on the Local Coverage Index. To view the information, select either “LCDs by Contractor” or “LCDs by State,” and check the box for “Future LCDs/Future contract number LCDs.” LCDs that have been converted to ICD-10 will be listed with an October 1, 2015, effective date.
With commercial payors, it is important that you have open dialogue with your provider representatives to ensure that you have all of the information that is available to be able to anticipate potential problems and address them in advance.
Vendors. Early in the planning process, one of the first steps in any ICD implementation plan was to ensure that you conducted a vendor inventory to identify which of your external vendors, including any software providers, would be impacted by the implementation of ICD-10. External vendors include clearinghouses, billing companies, computer-assisted coding software. At this point all software upgrades and enhancements necessary for the transition should be in place and appropriately tested so that any potential problems are identified and appropriately mitigated.
Any computer systems that are utilized in the revenue cycle process—from scheduling to bill submission (e.g., practice management, electronic health record, software and hardware systems)—should be double checked to ensure that patient problem lists, alerts, system interfaces and reports are compatible with ICD-10-CM. It also is important to appropriately estimate system down time (if any) expected during the implementation.
If your organization outsources its billing, or even just the coding function, it is very important that you confirm that the specific staff performing your