Lolita M. Jones, RHIA, CCS, independent coding and billing consultant, discusses six initial steps ambulatory surgery centers should take to prepare for the transition to ICD-10.
1. Form an ICD-10 steering committee. The first step in preparing for ICD-10 is to form a steering committee that includes representatives from nursing, billing and coding, physician leadership, administration and business operations. Since physician schedules are often packed, be sure to choose a physician who can really dedicate time to ICD-10 preparation. "That would be a physician who has a little more free time than the other physicians — maybe someone who's semi-retired and has a little more flexibility," she says. "It has to be more than in name only." The steering committee will be responsible for key action items involving ICD-10, including budget and training.
2. Plan for significant implementation cost. While current data on ICD-10 implementation in ASCs is hard to find, Ms. Jones cites data from 2009 MGMA study that predicted a three-physician practice would spend $84,000 to transition to ICD-10. "You could easily round that up to $100,000 for a single-specialty ASC, and for a multi-specialty, you're looking at going above and beyond," she says. ICD-10 costs include upgrades to existing software, databases and applications (SDA), consultants for training and assistance in the assessment of your existing SDA. Many of these costs will depend on your vendors' plans for ICD-10, Ms. Jones says.
3. Decide whether to train staff on ICD-10-PCS. ICD-10-PCS is a code set designed to replace volume three of ICD-9-CM for inpatient procedure reporting. The system will be used by hospitals and by payors rather than outpatient facilities, but Ms. Jones says ASCs should consider the possibility that commercial payors will want ICD-10-PCS codes. "I don't feel comfortable saying ASCs should ignore [ICD-10-PCS]," she says. "If the payor is exempt from HIPAA, they're still within their rights to request those codes."
4. Inventory all software, databases and applications in your facility. Once your steering committee is in place, you should identify the name, vendor and functionality for all software, databases and applications in the ASC. "Many ASCs have a separate product for accounting and a separate product for billing and another product for claims submission and clinical documentation," Ms. Jones says. "If they have one system that provides all of that, that's great because you're dealing with one vendor, but the reality is that most ASCs select [the product] that works best for a particular process and you end up with a ton of products." She says this process may take time; your ASC probably uses software without even thinking about its connection to ICD-10. Be thorough and ask each staff member to identify SDA you may have forgotten.
5. Contact your vendors. Once you have made a list of your vendors, you need to contact each one and ask about their ICD-10 implementation plans. "What do they need to do to [their] product? Do they need to expand field sizes or reconfigure reports? How will it affect their data dictionaries? How long will the vendor be able to support both ICD-9 and ICD-10? What kind of feedback are they going to accept on things that need to be tweaked before implementation?" she says. These are all questions you should ask to understand how the vendor will work with your ASC to prepare for the transition. Some vendors may require your facility to sign a new contract, possibly at an increased rate.
Ms. Jones advises ASCs to ask vendors to submit a plan for ICD-10 in writing. "I wouldn't rely on a vendor rep who says they're working on it," she says. "Get it in writing from the vendor on their letterhead." Ask the vendor for a plan, a projected timeframe and a contact person within the vendor organization, then establish expectations to keep in touch every two months in 2011 and every month in 2012.
6. Consider the clinical impact of ICD-10. In order to schedule the appropriate amount of training, your ASC should consider the impact of ICD-10 on documentation. Ms. Jones recommends ASCs use ICD-10 general equivalency maps to identify their most commonly-reported ICD-9 diagnosis codes and then identify the corresponding codes in ICD-10. "Look at documentation that will be required to continue coding those conditions effectively under ICD-10," she says. "For example, there are major changes to reporting of Barrett's Esophagus, which is a very common condition in [GI ASCs]. There are also a number of changes in documenting colon polyps."
A steering committee member should work with physicians to discuss additional documentation for ICD-10 codes. Start by addressing a topic at each departmental meeting, and ask physicians to start including more detail in their notes. "It's not wrong to put additional information in the H&P on a patient who, for example, has asthma as a co-existing condition," she says. "My recommendation would be to start building it in so that, come Oct. 1, 2013, the physicians don't even bat an eye."
ICD-10 may also have clinical implications beyond physician documentation. If your ASC reports quality improvement monitors on a state or national level, you may see QI initiatives change under ICD-10. Medical necessity guidelines may also change for certain payors, so a staff member should watch for publication of revised guidelines.
Lolita M. Jones, RHIA, CCS, is the author of the new book "ICD-10-CM/PCS Implementation Action Plan". Visit her website at www.EzMedEd.com.
1. Form an ICD-10 steering committee. The first step in preparing for ICD-10 is to form a steering committee that includes representatives from nursing, billing and coding, physician leadership, administration and business operations. Since physician schedules are often packed, be sure to choose a physician who can really dedicate time to ICD-10 preparation. "That would be a physician who has a little more free time than the other physicians — maybe someone who's semi-retired and has a little more flexibility," she says. "It has to be more than in name only." The steering committee will be responsible for key action items involving ICD-10, including budget and training.
2. Plan for significant implementation cost. While current data on ICD-10 implementation in ASCs is hard to find, Ms. Jones cites data from 2009 MGMA study that predicted a three-physician practice would spend $84,000 to transition to ICD-10. "You could easily round that up to $100,000 for a single-specialty ASC, and for a multi-specialty, you're looking at going above and beyond," she says. ICD-10 costs include upgrades to existing software, databases and applications (SDA), consultants for training and assistance in the assessment of your existing SDA. Many of these costs will depend on your vendors' plans for ICD-10, Ms. Jones says.
3. Decide whether to train staff on ICD-10-PCS. ICD-10-PCS is a code set designed to replace volume three of ICD-9-CM for inpatient procedure reporting. The system will be used by hospitals and by payors rather than outpatient facilities, but Ms. Jones says ASCs should consider the possibility that commercial payors will want ICD-10-PCS codes. "I don't feel comfortable saying ASCs should ignore [ICD-10-PCS]," she says. "If the payor is exempt from HIPAA, they're still within their rights to request those codes."
4. Inventory all software, databases and applications in your facility. Once your steering committee is in place, you should identify the name, vendor and functionality for all software, databases and applications in the ASC. "Many ASCs have a separate product for accounting and a separate product for billing and another product for claims submission and clinical documentation," Ms. Jones says. "If they have one system that provides all of that, that's great because you're dealing with one vendor, but the reality is that most ASCs select [the product] that works best for a particular process and you end up with a ton of products." She says this process may take time; your ASC probably uses software without even thinking about its connection to ICD-10. Be thorough and ask each staff member to identify SDA you may have forgotten.
5. Contact your vendors. Once you have made a list of your vendors, you need to contact each one and ask about their ICD-10 implementation plans. "What do they need to do to [their] product? Do they need to expand field sizes or reconfigure reports? How will it affect their data dictionaries? How long will the vendor be able to support both ICD-9 and ICD-10? What kind of feedback are they going to accept on things that need to be tweaked before implementation?" she says. These are all questions you should ask to understand how the vendor will work with your ASC to prepare for the transition. Some vendors may require your facility to sign a new contract, possibly at an increased rate.
Ms. Jones advises ASCs to ask vendors to submit a plan for ICD-10 in writing. "I wouldn't rely on a vendor rep who says they're working on it," she says. "Get it in writing from the vendor on their letterhead." Ask the vendor for a plan, a projected timeframe and a contact person within the vendor organization, then establish expectations to keep in touch every two months in 2011 and every month in 2012.
6. Consider the clinical impact of ICD-10. In order to schedule the appropriate amount of training, your ASC should consider the impact of ICD-10 on documentation. Ms. Jones recommends ASCs use ICD-10 general equivalency maps to identify their most commonly-reported ICD-9 diagnosis codes and then identify the corresponding codes in ICD-10. "Look at documentation that will be required to continue coding those conditions effectively under ICD-10," she says. "For example, there are major changes to reporting of Barrett's Esophagus, which is a very common condition in [GI ASCs]. There are also a number of changes in documenting colon polyps."
A steering committee member should work with physicians to discuss additional documentation for ICD-10 codes. Start by addressing a topic at each departmental meeting, and ask physicians to start including more detail in their notes. "It's not wrong to put additional information in the H&P on a patient who, for example, has asthma as a co-existing condition," she says. "My recommendation would be to start building it in so that, come Oct. 1, 2013, the physicians don't even bat an eye."
ICD-10 may also have clinical implications beyond physician documentation. If your ASC reports quality improvement monitors on a state or national level, you may see QI initiatives change under ICD-10. Medical necessity guidelines may also change for certain payors, so a staff member should watch for publication of revised guidelines.
Lolita M. Jones, RHIA, CCS, is the author of the new book "ICD-10-CM/PCS Implementation Action Plan". Visit her website at www.EzMedEd.com.