With a delay in the ICD-10 implementation deadline by at least one year, providers around the country are evaluating their next moves with regard to the code switchover. However, without specific guidance from the Centers for Medicare and Medicaid Services on the exact date, healthcare organizations that were well into the process of training and preparing for the ICD-10 transition are now left in a regulatory limbo.

Phoenix-based Banner Health, with 24 hospitals in seven states, started preparing for ICD-10 in November 2009. "We really in good faith started preparing for this project years ago," Linda Martin, IT operations director for Banner Health, told Health Data Management. "We've been doing training. We started testing. We've installed a number of different applications--computer-assisted coding--and we have a translation tool that we installed this year. And, we've been doing a lot of outreach with our payers."

"It's not that we were 100 percent prepared, but we were really working hard this last year to have everything in place," Martin added. "We were looking forward to completing this project, so we have really been taken back by the additional delay."

Banner Health is working on the assumption that the new ICD-10 implementation date is October 1, 2015, even though there has been no official announcement from CMS. "We have to have something that we are moving towards," said Martin. Like other health systems across the country, Banner Health is conducting an impact assessment of the ICD-10 delay to determine the path forward in terms of which organizational activities should stop, start or continue as part of their code conversion. All Banner departments will be directly or indirectly affected by this delay in the transition, she said.

ICD-10 training will continue at Banner Health, though Martin said more in-depth training will be deferred so that it doesn't take place too early in the ICD-10 preparation process. Working under the previous October 1, 2014 deadline, Banner's employed providers were previously required to take mandatory ICD-10 classes by May 15. However, as of now, no new date has been established. In addition, every provider must attend a general and specialty specific session. "We obviously will have to do some refresher training next year as we get closer," said Martin.  

Last month, before the ICD-10 delay, health information management coders at Yale-New Haven Hospital in Connecticut completed a three-day "boot camp" as part of more than 100 hours of online and classroom training required to prepare for the conversion from ICD-9 to ICD-10 codes. In March, the 1,541-bed facility--which serves as the primary teaching hospital for the Yale School of Medicine--also began training for clinical staff who will use the new ICD-10 codes. With the delay, the hospital now is evaluating the training schedule for non-clinical staff who use codes, including employees in patient access, radiology and billing, to ensure training occurs closer to the revised compliance deadline.

Banner Health is treating the ICD-10 delay as an opportunity to do more testing and to continue to work with payers to make sure they are prepared. "As much as our payers are ready, we do have a concern that our payers and our vendors will take their feet off the gas pedal so to speak," said Martin. There's also a significant financial cost to the ICD-10 delay for Banner Health. "All the resource time that we're expending on this--the project management and all our team members--has a cost," said Martin. "We also have applications that have licensing fees that will have to be extended for another year, specifically the translation tool. And, retention bonuses so that we don't lose our coders will probably be something that's going to need to be extended."

In Washington on April 22 and 23, the American Health Information Management Association is holding an ICD-10 summit to discuss next steps and provide examples of how healthcare organizations are responding to the ICD-10 delay. “While we continue to urge the Department of Health and Human Services to announce Oct. 1, 2015, as the new implementation date, we know that ultimately the transition to ICD-10 is inevitable,” said AHIMA CEO Lynne Thomas Gordon in a written statement.

So far, CMS has not provided guidance on the new deadline. The Protecting Access to Medicare Act of 2014, which included the provision that delayed ICD-10, prohibits adoption of the code sets until at least October 1, 2015. 

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