Author: Jason Gottlieb

The Transition to ICD-10

Jason Gottlieb

The healthcare industry’s transition to ICD-10 is transformation on a level not unlike the move to the Diagnostic Related Group (DRG) method of reimbursement in the early to mid-eighties. The revised format and increased level of specificity has the potential to change the way we access, deliver, and pay for patient care.

ICD-10 is a MONUMENTAL increase in the number of available codes. Diagnosis codes have increased nearly 500% from approximately 13,000 to more than 70,000. The increase in procedure codes is more than 2500% moving from merely 3,000 in ICD-9 to more than 80,000.

ICD-10 is MULTIDISCIPLINARY in both its impact to NYP and its transition efforts. ICD-10 is more than updating IT applications and training coding professionals on a new code set. The codes we use to describe the conditions of our patients and the services we provide to treat those conditions drives nearly every aspect of our operation. It drives clinical documentation, research and clinical trial efforts, our assessment of quality and patient safety indicators, managed care contracting, reimbursement, and can even play a role in our marketing efforts.

ICD-10 has been tagged as a catalyst in the MOVEMENT to a value, evidence based, population health system. The codified specificity of clinical factors such as disease state, anatomic site, causative agents and socio-economic factors such as financial hardship, inability to access care, and lifestyle choices have the potential to foster the development of detailed standards of care capable of producing successful clinical outcomes.

NYP is meeting this MONUMENTAL, MULTIDISCIPLINARY, MOVEMENT with a project team focused on achieving 9 milestones by the October 1, 2015 implementation date:

  1. Implement coding assistance technologies
  2. Enable provider support of ICD-10 documentation requirements
  3. Support hospital operations with an ICD-10 ready technology and data infrastructure
  4. Operationalize a dual coding production environment
  5. Complete end-to-end claims testing with insurance carriers
  6. Implement an ICD-10 ready resource model
  7. Manage the ICD-10 impact on quality and patient safety reporting
  8. Apply any necessary accounts receivable and revenue reserves
  9. Create an ICD-10 informed and insulated organization

Visit the ICD-10 AnTENna in the coming weeks for additional insight into each of these milestones and how NYP is coming together as an organization to prepare for the transition to ICD-10.

New ICD-10 Implementation Date Finalized

Jason Gottlieb

On Thursday, July 31, 2014, the Department of Health & Human Services (HHS) finalized the rule that establishes October 1, 2015 as the new implementation date for the healthcare industry’s transition to the ICD-10 diagnosis and procedure coding system.  Citing the potential costs along with other factors, the agency determined and ultimately decided that a one year delay was the most reasonable for all stakeholders affected.  Click here to read the Centers for Medicare & Medicaid Services (CMS) news release and here to view the actual rule as published in the Federal Register.

Interim rule to implement ICD-10 by October 1, 2015 arrives at the OMB

Jason Gottlieb

On Friday, June 13 (coincidence, omen, or both), the Office of Management & Budget (OMB) received the interim rule to implement the ICD-10 diagnosis and procedure code set by October 1, 2015.  Interim rules typically have a public comment and review period of 90 days, at which time, the OMB may publsh as originally drafted or modify based on those public comments.  Following that time line, it is possible that a final rule for ICD-10 implementation may be published in the Federal Register around the end of September.  Assuming the date does not change, that would give NYP and the rest of the healthcare industry one more year to ready itself for the new code set.

As we know, and have experienced, such rules are not written in stone and can be overturned by congressional actions similar to the fourth (yes… fourth) and most recent delay handed down in April of this year through its inclusion in the Protecting Access to Medicare Act of 2014.  In the interim, the industry, most notably the Workgroup for Electronic Data Interchange (WEDI) continues to pressure the Centers for Medicare & Medicaid Services (CMS) and the Department of Health & Human Services for more information, more education, and a stronger, more concrete testing and readiness plan to get the larger industry to embrace the transition.

WEDI issues letter to HHS requesting better management of the transition to ICD-10

Jason Gottlieb

In a letter to the Secretary of the Department of Health & Human Services (HHS), the Workgroup for Electronic Data Interchange (WEDI) requested improved management of the healthcare industry’s tranbsition to the ICD-10 coding system.  Among its 13 points of action, WEDI cited establishing credibility, more transparent communication of its own agencies readiness activities, a well defined testing process with published results, defined and tracked milestones, and generally more positive communication of the benefits ICD-10 will have on the delivery of healthcare.  The full letter to the secretary can be viewed by clicking here.

Centers for Medicare & Medicaid Services (CMS) first public comments on ICD-10 delay

Jason Gottlieb

In its first public comments since the implementation of the most recent delay to the implementation of ICD-10, CMS’ Acting Deputy Director, Office of E-health Standards & Services (OESS), Denise Buenning addressed hundreds of attendees at the American Health Information Management Association (AHIMA) ICD-10 Summit in Washington, DC. Click here to read the full article.

Coalition for ICD-10 Presses for new ICD-10 Implementation Date

Jason Gottlieb

The Coalition for ICD-10, a broad-based healthcare industry advocacy group, including— hospitals, health plans, hospital and physician office coding experts, vendors, and the health information technology (HIT) community— united in support of the U.S. adoption of the ICD-10 coding standard, sent the following letter (click here) to the Centers for Medicare & Medicaid Services (CMS) Administrator Marilyn Tavenner dated April 11 urging the Department of Health & Human Services (HHS) to establish October 1, 2015 as the new implementation date for the ICD-10 diagnosis and procedure coding system. The recent resignation of HHS Secretary Kathleen Sebellius further complicates the currrent state of ICD-10 implementation across the industry and a timeline for the new implementation date.

ICD-10 Implementation Date Delayed

Jason Gottlieb

ICD-10 Project Leadership and Participants

At approximately 6:59 PM Easter Standard Time (EST) on Monday, March 31, 2014, the United States Senate, by vote of 64 – 35, elected to pass H.R. 4302, legislation that installs the 17th consecutive temporary fix to the sustainable growth rate formula (SGR) for Medicare payments to physicians.  This bill also includes the previously mentioned clause to delay the implementation of the ICD-10 coding system until a minimum of October 1, 2015.  All indications are that President Obama will follow the lead of his legislative counterparts and sign this bill into law.

NYP, by all estimates, continues to be ahead of the industry curve in its readiness and adoption activities.  We will continue to fine tune our understanding of the potential impact of ICD-10 on all aspects of hospital activity – clinical, operational, and financial.  We will also monitor the relevant industry, regulatory, and legislative channels for clarity on the new implementation date.  However, in absence of such a date, I will be looking to convene project leadership to establish a more formal position and go forward strategy for NYP

This most recent development and delay is assuredly frustrating to many who have worked tirelessly amongst many, many competing priorities to ensure NYP’s people, processes, and technologies were not only ICD-10 ready but ICD-10 operational well in advance of the October 1, 2014 implementation date; a goal that we largely achieved for many aspects of the hospital operation.  These efforts are not unrecognized and will continue to contribute enormous value whenever the United States government in conjunction with the Department of Health & Human Services (HHS) and Centers for Medicare and Medicaid Services (CMS) decide to implement ICD-10.  Once again, I’d like to thank all members of the team for those efforts.

Potential Delay of ICD-10 Implementation Date

Jason Gottlieb

Earlier this afternoon, the United States House of Representatives passed by way of a voice vote, H.R. 4302 which primarily includes provisions to install another temporary fix to the sustainable growth rate formula for physician payments.  Included in this passed legislation is a provision that would not allow the Health and Human Services Secretary to implement the ICD-10 coding system until at least October 1, 2015.

It is important to stress that the implementation of ICD-10 has not been delayed at this time.  The current legislation has passed in the House of Representatives only.  It still must pass a vote in the Senate as it is currently constituted and finally be signed into law by President Obama.

As has been NYP’s method of operation for the past 2 plus years, we will continue to move forward with the expectation that ICD-10 will be implemented on October 1, 2014 until otherwise informed.  I’d like to thank all members participating in the ICD-10 project for their continued leadership, efforts, and support.