The switch to newer diagnostic and procedural codes to meet compliance for ICD-10 no doubt has been weighing heavily on the minds of healthcare leaders across the industry for quite some time. Due to the complex structure of the codes, the process of implementing and testing the changes is expected to be time-intensive and costly.
What's more, with the recent declaration by CMS Acting Administrator Marilyn Tavenner that the ICD-10 deadline would not be pushed out a second time, providers who had been hoping to postpone those efforts to instead focus on other projects now must plan accordingly, or risk not being paid once the Oct. 1, 2014 deadline hits.
Christine Armstrong, principal at Deloitte, recently spoke with FierceHealthIT about where providers are in that process and what remains to be done.
FierceHealthIT: How are you feeling about the timeline and the amount of work that's been done so far?
Armstrong: It seems that most people have a lot of work ahead of them. Some organizations jumped ahead, then with the delay, they stopped, then had to regain momentum. Most providers--and that includes hospitals and physicians--still have a lot of work ahead of them.
There still are quite a number of organizations that haven't started their planning yet, and we certainly would encourage them to do that. The organizations that are in implementation now are finding that it's taking longer than they originally thought, whether it be training or education or working with their vendors to get their systems upgraded or their testing plans--both internal and external. The time that it's taking, with everything else they have on their plate, is just taking longer.
FierceHealthIT: What are the particular frustrations?
Armstrong: Most people just want the date to stick, to know that is their end game. The challenges that people are encountering have to do with everything else going on in the healthcare industry at the same time. Preparing for Meaningful Use, the impacts of healthcare reform, looking at cost reduction, resource constraints, and preparing for ICD-10 just poses challenges for a lot of organizations.
People are worried about all these initiatives and timelines kind of superimposing on one another. Making sure you have the right resources is becoming a bit of a challenge, so again, the more time you give yourself to prepare, the less of a crisis activity you'll be in.
FierceHealthIT: In your recent paper, "Ten Things to Know about ICD-10 Implementation for Providers," did some frustrations stand out more than others?
Armstrong: One thing we're seeing with clients in the midst of implementation is that the testing is more complex because you're not just testing one system, you're testing multiple systems. So you're having to do internal integration testing, then you're having to do testing outside your environment. You're having to export data to payers for collaboration testing and also for third-party trading partners. So anybody you're sending data out to today with ICD-9, you'll have to test with them.
At the same time, you're trying to make sure your vendors are going to keep up with your timeline, that they're going to give you upgrades in a way that will allow you to test your interfaces and integrations. It's becoming a challenge because you can't control everything.
FierceHealthIT: According to the paper, manufactured data should not be the only data used in testing. Do you run into HIPAA concerns if you're using anything but manufactured data?
Armstrong: You need to natively code some claims. You can use masked PHI for the testing, but don't just cross-map to get your ICD-10 codes. Sit down and natively code claims so you have a subset of claims. If not, you're never going to get the real experience.
We're urging people toward early adoption so you get some practice time in. If you code in both ICD-9 and ICD-10 for a period before the go-live date, you get a multiple bang for your buck out of doing that and you're not just using manufactured data. The outcomes are different, so you need to see how your reports look differently. Things like case mix index will be different if you natively code those claims.
FierceHealthIT: Are physicians involved at this point?
Armstrong: Most of the clients we're working with have engaged their physician leadership at this point as part of their governance structure. They have worked with physicians to understand what are the best ways to plan for training. Many of the physicians in the governance structure have been working on these electronic health record enhancements. In many of the clinical documentation improvement programs, they've trained their clinical documentation specialists so they can have these gentle discussions with clinicians about things we need to document differently. Most organizations are not doing their online physician training yet. That probably won't come until the first quarter of 2014, but to be ready to go, you need to engage your physicians in the planning process.
FierceHealthIT: What is your advice for those who haven't started the conversion process yet?
Armstrong: If you haven't done anything, you really need to move quickly. At this point, we're recommending that organizations not do a full-blown assessment, because you don't have time. But maybe do an accelerated assessment and get your systems inventoried, get your training plan together and develop your strategies; then move into implementation, so you're starting to move forward. Build yourself a work plan and get a good governance structure in place.
This interview has been edited for length and clarity.