ICD-10 Rollout Suggestions For HHS

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The Department of Health and Human Services delayed the ICD-10 code implementation until October 2015, but that doesn't mean implementing the new classification system should be far from healthcare IT professionals' minds, according to the Workgroup for Electronic Data Interchange (WEDI).

In fact, the healthcare industry should use the additional 12 months as an opportunity to be better prepared for the revised timeframe, says Devin Jopp, Ed.D, president and CEO of the nonprofit association that includes healthcare providers, health plans, vendors, government agencies, consumers, not-for-profits, and standards development organizations. Founded in 1991, WEDI was designated in the 1996 HIPAA legislation as an advisor to HHS. In that capacity, the group submitted an outline of recommendations on how the department could improve its ICD-10 roadmap.

Once stalwart in its commitment to the ICD-10 deadline, when Congress and President Barack Obama delayed the update, the Centers for Medicare & Medicaid Services (CMS) announced it would not accept any ICD-10 coded claims until the 2015 deadline.

That means even the best-prepared healthcare providers cannot test their ICD-10 systems in real-world situations, and slower facilities have no incentive to move faster to adopt the newer coding solution.

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Each delay causes ripple effects -- and expenses -- for healthcare organizations, making it imperative for the government to get ICD-10 right, executives say.

"There is an incredible amount of extra overhead that is carried through a delay. You might have acquired some analysis and testing tools through license. So you might have subscribed to that license for a year, and now, all of a sudden, you have to extend that license period with that vendor, so now you may have additional material costs," say Erik Newlin, co-chair of the ICD-10 Assessment Workgroup at WEDI and director of National Standards Consulting for Government Healthcare Solutions at Xerox, in an email.

"If you had a testing period that was scheduled for external testing that was to be completed by the original 2014 date, now what do you do with those staff? Can you reallocate them to something else? Or do you have to release them because you can’t keep them on your books for eight or nine months? Each possibility comes with its own risk and complications that need to be carefully considered." 

Repeat performance?
If past performance is an indicator, delaying ICD-10 by a year will make little difference to procrastinators. Many healthcare organizations were slow to move toward ICD-10 last year. When ICD-10 had an October 2014 deadline, many practices expressed optimism about their preparedness, despite an apparent lack of activity, according to multiple studies. In fall 2013, for example, 22% of those polled had not started preparing, but 55% were confident or very confident they would meet the 2014 deadline and 42% were somewhat confident, a Navicure survey found.

Likewise, WEBI discovered an implementation slowdown among its members. About two thirds of health plans started or expected to start internal testing by the end of 2013, down from the three quarters who predicted they'd be in that position in a February survey. Approximately one-fifth of vendors were halfway or less than halfway through testing, a much smaller number than in the prior survey, although only one-fourth had completed the process.

The same situation could happen in 2015, as healthcare organizations once again postpone ICD-10 implementations, leading to errors with billing and patient records. Prompted perhaps by repeated delays, lack of management backing or funding, or vendors' non-compliance, healthcare providers might discover they cannot address ICD-10 when the 2015 deadline arrives.

WEDI hopes to reduce that risk. In its letter, the organization recommended that HHS:

"It's ultimately our responsibility as an industry to out how to do it together," says Jopp. "What we don't want to be is back in the same position where we're in the spring of 2015, and we're back in the external testing stage."

Establishing clear milestones that healthcare executives could check off would help organizations achieve ICD-10 certification, he says. HHS could, perhaps, use the Office of the National Coordinator's (ONC) Regional Extension Centers (RECs) to help providers achieve ICD-10 requirements, he adds.

Practice management software, critical to organizations' daily operations, currently has no ICD-10 accreditation program, and that's something the industry needs, he says. WEDI recently partnered with EHNAC to develop a practice management system accreditation system to meet HIPAA and ICD-10 requirements, among other criteria, he says.

"You always have your left and your right on every issue, but WEDI never positions it on whether we should or should not do ICD-10," Jopp says. "We're committed to making this work, but these are the things we're going to have to do and it's not going to be business as usual to many. There are a lot of moving parts to this we have to consider."

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