There has been a great deal of discussion surrounding Centers for Medicare & Medicaid Services’ (CMS) delay of the ICD-10 start date, which has now been officially extended one year to October 1, 2015. Response to this news has been mixed and regardless of whether you are a provider or ICD-10 vendor this delay offers both opportunities and challenges. The largest advantage for providers is the additional time to prepare for the changeover. The largest disadvantage is tied directly to cost and the provider’s bottom line.
Some of the key challenges providers will face include:
- Retraining physicians, coders and compliance/audit teams
- Additional costs for testing new ICD-10 updates leading up to the 2015 start date
- Dual coding for a longer timeframe
- Extension of internal resources and consultants
- Efforts expended on ICD-10 that could have been directed towards patient care
- At least part of the ICD-10 vendors’ cost of time and resources already spent will be passed along to the customer
Impact on Vendors
The companies that develop and sell coding solutions will also feel the effects of this postponement. On the upside, it provides more time to improve their products with added enhancements and functionality. However, this also means a delay in realized revenue for vendors that may result in price increases for the end user.
For those who are playing catch-up, it’s not too late to benefit from some of the guidelines and best practices developed by early adopters. Among these are the following:
- Establish a focus committee to manage the process.
- Be proactive. Just because the start date has been extended, don’t wait to get started or put things on hold for too long.
- Consider engaging a consultant to help guide you through the process.
- Identify changes to internal processes that need to be made (e.g., diagnosis coding tools, super bills, public health reporting tools, etc.).
- Coordinate with practice management/EHR vendor(s) regarding ICD-10 upgrade availability.
- Work with clearinghouses, billing service, payers, etc., on a testing plan strategy.
- Create and implement a staff training plan. Assess the knowledge level and training needs of the staff and customize training accordingly.
- Plan to utilize dual coding (ICD-9 and ICD-10) for several months prior to the start date.
- Perform internal testing of transactions with ICD-10 codes, including analytics and reporting tools to mitigate risk.
With the new October 1, 2015 start date, all HIPAA covered entities will be required to continue using ICD-9-CM through September 30, 2015. The changed date issue aside, many recognize the potential advantages associated with the migration from ICD-9 to ICD-10. ICD-9 is over 30 years old and considered by most to be an out of date system with limited ability to expand the code set or add new codes. The 14K diagnosis codes in ICD-9 expand to 68K in ICD-10 and the new format offers greater granularity and more specific information about the diagnosis.
There are numerous anticipated benefits for providers associated with the migration to the more robust ICD-10 system, including:
- Enhanced ability for quality and safety measurement.
- Access to additional data that can be used in data mining and research efforts (e.g., disease pattern analysis).
- Greater efficiencies in the reimbursement process with more accurate and equitable payments and fewer payment delays and investigated/rejected claims.
- Expanded flexibility for future updates.
- Helps the U.S. catch up to technology already in use in other parts of the world.
The ICD-10 initiative is daunting and comes with inherent headaches, challenges and financial burdens. However, many are hopeful that hindsight will prove the effort worthwhile if it contributes to the ultimate goals of projected cost savings and improved patient care.