"The first thing we are doing is mapping our data," advises Bowen, who serves as president-elect of the American Health Information Management Association, Chicago. During Erlanger's preparation, the health system discovered that-unbeknownst to HIM staff-various information systems had been using ICD-9. That means these "surprise" systems have to be included along with other systems when migrating to the new ICD-10 codes.
Consequently, ICD-10 compliance work is a good opportunity to create a roadmap showing where your data is, what type of data it is and how it is used, she adds. But the biggest challenge for HIM departments will be education of coders and other ICD-10 users, Bowen and other HIM directors believe.
"ICD-10 will affect HIM more than the business office," contends Julia Kendrick, corporate HIM director at Ardent Health Services in Nashville, Tenn. "We have to completely retrain our coders. They have been using ICD-9 for as long as they can remember."
The level of anatomy and physiology detail in ICD-10 codes has greatly expanded, creating a need for better educated coders, Bowen says.
The big fear for providers, many experts say, is that veteran coders near retirement won't stick around for the education and retraining. But small-scale testing that AHIMA did with Ohio State University showed that experienced coders quickly learn to understand the vastly larger coding set, says Sue Bowman, director of coding policy and compliance at AHIMA. "So no one should be afraid of the increased number of codes. And the average physician practice will only use a small fraction of the codes."
Bowman cautions health care organizations to avoid early training of ICD-10 users. "This type of training is most effective if done six to eight months before the implementation date," she says.
Realistic Date?
Transitioning to ICD-10 will be a task equal to the implementation of Diagnosis Related Groups two decades ago, Kendrick says. So, there's considerable work to be done before the proposed compliance date of October 2011.
But that compliance date is dependent on how fast the Centers for Medicare and Medicaid Services publishes a final rule to implement ICD-10. CMS Acting Administrator Kerry Weems is pushing for a final rule in late 2008. Work on the rule would be delayed during the transition to a new presidential administration in early 2009, Weems says.
Many in the industry believe that the compliance deadline will slip, says Rachel Chebeleu, director of medical records at the Hospital of the University of Pennsylvania in Philadelphia. She's concerned about vendors and insurers being ready.
But readiness also counts for providers, particularly physician practices, adds Rex Stanley, R.N., CEO of coding vendor UnicorMed in Montgomery, Ala. He doubts, however, that the October 2011 date will stand. AHIMA and the American Hospital Association are the only organizations that really think that date is realistic, Stanley contends. "CMS doesn't even think that."
Many vendor CEOs, Stanley contends, won't spend the money on ICD-10 compliance until there is a drop-dead deadline. "There will be vendor problems but payers will be worse," he predicts.
Weems of CMS, who expects to leave his post when the Bush administration ends, did not rule out the possibility of a contingency period.
Early Work
By the end of 2008, organizations should know the proposed rule well and have an initial compliance plan in place, says Laurie Johnson, senior HIM consultant at Ingenix Inc., an Eden Prairie, Minn.-based software firm. "It's not just vendors. Hospitals and anyone else dealing with coded data need to do this."
Provider organizations need to goad vendors into action, says David Hochheiser, an Ingenix vice president. The company expected in late 2008 to start sending customers information about ICD-10 migration and what they need to do.
"Start doing a gap analysis of how ICD-9 currently affects business - what technologies and processes are based on ICD-9," he advises. "You're going to need to know all the touch points of the new system."
One overriding reason for early work on ICD-10 compliance should be stressed to senior executives. "Our health care system is based on good coding," says Hochheiser, echoing many experts.
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