ICD-10 CM is going to impact the entire home health industry and every department of your agency. Now that we know that the implementation date will be October 1, 2014, agencies need to establish a solid plan now. You need every day of the 24 months to educate, plan, educate, implement, reevaluate, test and retest, and educate. Training for coding specialists is important, but training for those who will use the data will be equally important.
Creating a roadmap for ICD-10 integration within an organization may appear daunting. Let’s break down the process. CMS suggests presenting an overview of ICD-10 to the entire organization. This allows individuals to process the changes in ICD-10 and align those changes to processes they presently complete. This assists the organization to understand the depth and impact of ICD-10.
Completing the Gap Analysis
Define the agency’s present state. Review the list of processes for each department from intake of a potential patient to filing of the final claim of the patient and the resulting data analytics. Identify how the coding touches each area of work flow.
Identify the agency’s strong competencies and the additional training to maintain those competencies. Look at performance levels and consider the impact of ICD-10 on performance. Considering the increased specificity of ICD-10 coding, what will be the impact on clinical and operational processes? What new clinical tools will be needed? What form changes will be required? How will internal and external reports be impacted?
List, then communicate with vendors, payor sources, and clearinghouses. Where are they in their processes? What are their plans? Will they be ready?
Identify the timeline for the Gap analysis.
Organize an ICD-9/ICD-10 Transition Team
The goal of the team is to establish an overall organizational plan after the Transition Team either completes or receives from another committee, a Gap analysis; operational and technical impact analysis. The new Transitional Team should review that overall analysis, using those specific organization findings to provide the base of their project/transition plan.
The Transition Team should have representatives of each department: intake, clinical, IT, HIM, billing, QA, internal auditing, and administration so that they can adequately develop an expansive implementation strategy.
Choose a project leader of the transition team. This leader must organize the development of a budget, a timeline and action/project plan that will include a training plan for the organization. It must demonstrate how findings and planning will be communicated. The project/transition plan needs to be tied to endpoints that are reasonable and measureable. Compliance plays a huge role. The plan must be compliance oriented; attending to statute, convention, guideline and regulation.
Report from each Department Representative and Plan Creation
The representative from each department; IT/technology, Clinical, Coding, Revenue Cycle/billing/finance, QA/QI/Audit, Data Analytics, and Education/Training must lead the indepth department evaluation as well as the department project plan.
What will be the impact to each department?
Impact on data capture at intake? At time of assessment? On data analytics and reports?
Impact on the plan of care (485)? Consistency of diagnosis/supportive documentation/careplan
What about the schedule and the depth of schedule notes?
Utilization and quality process and improvement
Need for increased clinical cues
Time/ amount to capture data at all time/patient points
Field sizes, alphanumeric composition, and decimal use
Code value alteration with Table structure alteration
Edit and logic changes
Overlapping time point of ICD-9 and ICD-10
Impact on the EMR
Impact on interfaces
Impact on HR and personnel needs
Education and training needed for each department
Budget creation for the project
Who will monitor the vendors and payors?
Do not trust the statement that the vendor will be ready. Your agency cash flow could be dependent upon their planning, testing, and implementation.
Ask to see the vendor plan and monitor progress to general goal completion. When will the upgrades or new software be available?
Evaluate health plan readiness. Evaluate the impact of ICD-10 on usual and customary reimbursement fee schedules as well as episodic reimbursement.
Training and Education
You want to prevent agency claim rejections as well as delays in processes. You want personnel comfortable with new processes. You want to be compliant.
Each department will have different training needs. Obviously, the biller does not need the same level of coding expertise as a credentialed coder, but they require an understanding of the impact of the new coding on their particular processes.
The leader of this department will need to work closely with each department head as to specific training needs as well as the best methods of training. Additional assessments needed include: Can the agency provide all, some, or none of the training needed? What training method will work best for the learners? Will classrooms and teleconferences work best? Should they be augmented by web-based learning? Are inservices and seminars by experts another route to pursue?
Consider length of time for education and training. Some departments will require more training over a longer period of time.
Coders will need an indepth review of Anatomy, Physiology, Pathophysiology, Diagnostics, and Pharmacology. Each of these areas should be relational to disease states so that a comprehensive understanding of the new code application exists.
Whether you code inhouse or you contract with outside experts, be certain that parallel coding will occur for several weeks before the new codes are applied to the claims. October 1, 2014 should mean all training and education has been completed, processes have been reviewed and tested. Be certain that data analytics and infomatics are meeting the new specificity requirements.
Clinicians will need a solid understanding of the specificity of the documentation now required. They will need orientation to the more indepth assessment tools. Clinical cues as to diagnosis documentation requirements will be needed.
Hopefully, vendors will be able to assist clinicians so technology can be leveraged to make up for the detailed documentation needed.
October 1, 2014 will be the ICD-10 implementation date. You have only 2 years to complete the Gap analysis, establish the Transition Team, create the transition plans, lead and evaluate training/education needs of all departments, create new tools needed, modify and test processes as well as review data created and have all processes in place to submit compliant claims. You need to start NOW! You only have two years and the clock is ticking.