"It's a change of such momentous proportion," says Jacobs, director of IMA Consulting. "It is unlike anything that has happened to the industry." Even the introduction of diagnosis-related groups, the foundation of prospective payment, pales in comparison, she adds. "DRGs did not affect every single department like I-10. This is a change that will affect every single functional area in the hospital, every person and system that touches a claim. We don't really know what will happen in 2014. I do envision a lot of claim rejections."
The consultant is not alone in her anxiety. The industry for the most part is still in the ICD-10 planning stages, but as it gets deeper into the task, and hears from organizations that have made some headway with ICD-10, the grim reality of transitioning to ICD-10 is starting to settle in. And all too many stakeholders are having to scramble to craft transition strategies, set up executive-driven governance structures and complete internal systems impact assessments.
The I.T. side of the house also is starting to get a better idea of just how much work they'll have to put in. The transition will require remediation of any system housing ICD-9 codes-which, it's increasingly obvious, means just about anything in the clinical documentation and revenue cycle arenas. But systems remediation is not the sole job that needs to be done. Providers are also analyzing any likely revenue hit under ICD-10-which will require vastly more detailed documentation than physicians currently provide in order to submit a clean claim. Witness the sudden emergence of "CDI" initiatives, short for clinical documentation improvement. And they also are looking at likely areas of lost productivity, particularly among coders-a group which will have to learn the equivalent of a foreign language, one interlaced with concepts not present in their native tongue. Productivity concerns are a prime reason why many providers are adopting computer-assisted coding software (see related story).
The wild card is the actual ICD-10 compliance date. CMS has postponed its implementation several times, even after asserting that the most recent ostensible go-live date of October 2013 was etched in stone. The American Medical Association also seems to be trying to keep that deadline on the far horizon, even suggesting that the industry skip to ICD-11, which is not yet ready for prime time (see sidebar).
The delays leave the United States in the dubious position of being one of the last remaining industrialized nations not yet on the coding system, which was crafted by the World Health Organization. Canada, for example, implemented ICD-10 nearly a decade ago. "The move to ICD-10 is long overdue," says Jacobs, echoing a near-unanimous sentiment among data quality experts. "We can't afford to keep delaying. There have been so many advances in medical technology that can't be categorized in ICD-9."
Late to the party
Now, pending publication of a final rule, the go-live presumably will be 2014. But the series of delays has cost the government heavily in the credibility department, many observers say, and as result, only undermined the seriousness of the transition. "With the most recent delay, many in the industry knocked the project to the back burner," says Bob Schwynn, principal at Aspen Advisors, an I.T. consultancy. "It is hard for the C-suite to take the government seriously."
That may explain why the industry is behind schedule in transitioning to ICD-10. "The industry is moving forward slowly, but not moving forward fast enough," says Jim Daley, chair-elect of WEDI, a non-for-profit industry group of 300-plus provider, payer and vendor members promoting electronic data exchange. "Most are aware of ICD-10, but there are so many other priorities they are not focusing on it." WEDI has surveyed its members regularly on ICD-10 for three years, and has devised its own ideal timeframe for making a smooth transition. By any measure, the industry has fallen behind where it needs to be, Daley says.
According to WEDI's most recent readiness survey (completed in February 2012), half the providers "did not know" when they would complete their impact assessment-a critical first step which drives all other planning-while only a third of payers had finished it.
In another survey of payers, conducted by claims management software vendor HealthEdge, 61 percent of health plans said they could meet an October 2014 deadline, with 30 percent saying they could "likely meet" it, notes Ray Desrochers, executive vice president. "If you prod, they are all over the map as to what 'likely' means," he cautions. "There is a lot of hesitation, angst and anxiety over ICD-10. Many payers underestimated the effort."
Schwynn of Aspen says the most difficult part of the ICD-10 transition is governance. Given its scope, the transition to ICD-10 cannot be driven solely by I.T. or HIM, he says, even though those two departments will be among the hardest hit. Schwynn advises forming an executive sponsorship group that includes a senior executive from both the finance department and the medical staff. Beyond that, a single coordinator or project leader is a must to oversee the multiple departments affected by the change. "Getting everyone around the table is a huge governance challenge," he says.
Schwynn's suggested governance model is in play at select health systems seeking to stay ahead of the ICD-10 curve. North Shore LIJ Health System, which runs 16 hospitals in the greater New York area, launched its transition effort in the fall of 2010.
"Given our size and breadth of services, and the size of our I.T. portfolio, we started early," says Tom MacMillan, who serves as the ICD-10 program manager, office of the CIO. North Shore LIJ's governance model is driven by a senior level steering committee which includes the enterprise CIO and several vice presidents, from financial and clinical areas, as well as some local hospital CEOs, he says.