ICD-10 implementation was delayed by at least one year with the passage of the Protecting Access to Medicare Act of 2014. The Centers for Medicare and Medicaid Services has yet to announce a new official deadline and many in the in healthcare industry remain unsure of what to do next. Betty Gomez, head of regulatory strategy with ZirMed, explains how the ICD-10 delay affects ambulatory surgery centers and ASC physicians and how to use the extra time to refine preparations for the new code set.
Question: How will the ICD-10 delay affect ambulatory surgery centers?
Betty Gomez: It really depends on where the surgery centers are in their ICD-10 preparations. Where you stand is correlated with your readiness position. Those centers that have procrastinated will be relieved, and those who have spent the time and money necessary to be ready may feel annoyed and betrayed.
If you have procrastinated and didn't prepare, you now have an opportunity to get back in track and start your preparations now just because there's a delay doesn't mean that you can wait to start your preparations. Remember it takes a lot of time to have everything in place, such as your systems upgrades, workflow and processes adjusted, your physicians and coders trained and of course testing all the changes to ensure readiness. If you don't take this opportunity you will find yourself in the same dilemma not totally prepared and with great financial risks. You want to make sure you minimize your potential to slow A/R days and productivity levels. Make sure you take advantage of this additional time provided.
If your center was ready to rock and roll on October 1, 2014 then you will feel the impact of the delay as you now will have to make sure that your system will be able to continue to support ICD-9 after October. You probably have invested a lot of time and effort and money into your preparations and now you will need to figure out how best to make use of what you have already accomplished.
Q: Are there negative and positive effects of the delay for ASCs?
BG: There are both positive and negative effects. Let's look at the positive ones first. If your organization was on their way to being ready by October 1, 2014 you now have an opportunity to take a good look at all your processes and refine them. Make sure your vendors will deliver on their stated timelines hold them to those timelines; if they change their delivery dates this will impact your timeline and preparations specially around testing.
With the delay you can now take advantage of additional time to test with your payers and embark on end-to-end testing with those payers that are supporting it. Seek out opportunities to test with payers — be persistent and proactive. Testing is a very critical part of this implementation process and will provide great insights into how well your organization is prepared, how well your physicians are documenting and how well your coders are coding. Remember — the more you test, the fewer rejections and denials you'll experience when ICD-10 does go live.
With the additional time you can help your physicians and other clinicians see the value of continuing to create clinical documentation detailed enough to support ICD-10 coding now. The increased specificity that ICD-10 requires — such as laterality, trimester, and smoking status — has implications and benefits far beyond ICD-10. Detailed clinical documentation will help your coders select more specific ICD-9 codes, which are less likely to be rejected or under-reimbursed. In addition, many of these details are required to meet PQRS standards — and detailed documentation improves the quality of health records and reduces your organization's risk of medical errors caused by missing or incomplete information.
One negative effect and where a lot of organizations are struggling today is in the resources and funding area. This one year delay won't be cost neutral; there will be some incremental cost to waiting an additional year. Executives are not fond of continuing to invest in this mandate. There's a struggle over what the right thing to do is and how much will that right thing cost. The one lesson that was learned in the past was that if you pause or slow down your preparations until a new date is established you will have a hard time rejuvenating the momentum and getting people engaged. You might lose your funding and it might be hard to get going again.
Another downside is not knowing what the new date is, without this date it will be very difficult to make the decisions you have to make.
Q: How will the delay affect ASC physicians?
BG: We really won't know exactly how it will affect them until we have clarification from CMS as to when the new date is, if it's delayed one year or more than one year. The one key thing here is to not completely stop efforts to prepare.
As we all very well know it does take time to really be ready. I'm afraid if the ASC physicians check out they will be in the same position that they are today not being completely ready when the new date comes around. One thing is true time goes by quickly and when we least know it the new date is right around the corner. We need to make sure we keep the momentum going and not rush through our preparations.
External coordination and external dependencies need to be examined. Last time many vendors delayed ICD-10 compliant releases which had a domino effect on what physicians had to prepare for. They had to change milestones of key deliverables they were dependent on. What's the in or out strategy? As clients are more mature in readiness consider impact of processes since there will be a one or more year delay.
Physicians need to make sure they continue on a portion of testing so they can get their upgrades in and enable the next phases of their work like finishing their EHR implementation, meeting all of the MU stages. Some of the current day activities can continue to support these future efforts.
Q: What should ASC leaders be doing with the additional time before implementation?
BG: • Ensure all their systems have been upgraded and ready to go.
• Continue with their clinical documentation improvement plans which can be used in today's coding to help select more specific ICD-9 codes, which are less likely to be rejected or under-reimbursed.
• Spend more time testing both their internal systems and external end-to-end with payers and remediate processes and systems as needed.
• If you have trained coders already in ICD-10 keep them on the path to greatness. Provide them opportunities to practice their new founded knowledge — ask them to code at least a few claims in ICD-10 every week, or challenge them to master a subset of claims that are particularly difficult to code or that have especially high impact on your organization's bottom line. Coders who stop using their ICD-10 skills will lose them, while coders who further develop these skills will be the best in the business.
• If you don't have ICD-10 trained coders, allow them to get familiar with ICD-10 and ensure that a good training program is in place. Consider dual coding opportunities.
• Remember with the additional time you know have to opportunity to really get everything in place and not rush through or skip any of the steps. You can now ensure your productivity levels won't diminish.
• Don't become complacent, hold your vendors accountable and test, test, test.
Q: Do you think there are any mistakes ASC leaders made during their initial ICD-10 preparation that can be avoided with this additional time?
BG: We do have lessons learned from the previous time this mandate was delayed, such as underestimating the time required to get ready. Some leaders didn't recognize the magnitude of this change and thought they still had plenty of time to get ready. They need to recognize the importance of improving their documentation, training their coders and ensuring that they test both internally all of their upgraded systems and processes and engage their clearinghouse, external party entities and payers in testing more specifically end-to-end testing.
They now have the time to ensure that everything is in place and to test and refine their processes and workflows. They can also apply the results of their testing to put together a good risk and mitigation plan in place and make the appropriate corrections or adjustments to their processes from the information obtained during their testing activities.
Recognize the importance of proper clinical documentation. This is something they can take advantage of improving now and making their current ICD-9 coding more specific.
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