icd-10 milestones · icd-10 represents a significant impact to it applications and business...

WEDI Strategic National Implementation Process (SNIP) ICD-10 Workgroup ICD-10 Transition Sub-workgroup

ICD-10 Milestones April 2, 2015

Workgroup for Electronic Data Interchange 1984 Isaac Newton Square, Suite 304, Reston, VA. 20190

T: 202-618-8792/F: 202-684-7794 2014 Workgroup for Electronic Data Interchange, All Rights Reserved ICD-10 Transition ICD-10 Milestones Whitepaper

Contents Disclaimer ............................................................................................................................................................ 3 Purpose ............................................................................................................................................................... 4 Scope ................................................................................................................................................................... 4 Introduction ........................................................................................................................................................ 4 Organization of this document ........................................................................................................................... 4 Plan, Organize & Assess ...................................................................................................................................... 5 Communication & Outreach ............................................................................................................................... 6 Remediation ........................................................................................................................................................ 7 Testing ................................................................................................................................................................. 8 Training ............................................................................................................................................................... 9 Transition .......................................................................................................................................................... 10 Conclusions ....................................................................................................................................................... 11 Acknowledgements .......................................................................................................................................... 11 ICD-10

Transition ICD-10 Milestones Whitepaper

Disclaimer This document is Copyright © 2015 by The Workgroup for Electronic Data interchange (WEDI). It may be freely redistributed in its entirety provided that this copyright notice is not removed. It may not be sold for profit or used in commercial documents without the written permission of the copyright holder. This document is provided “as is” without any express or implied warranty. While all information in this document is believed to be correct at the time of writing, this document is for educational purposes only and does not purport to provide legal advice. If you require legal advice, you should consult with an attorney. The information provided here is for reference use only and does not constitute the rendering of legal, financial, or other professional advice or recommendations by the Workgroup for Electronic Data Interchange. The listing of an organization does not imply any sort of endorsement and the Workgroup for Electronic Data Interchange takes no responsibility for the products, tools, and Internet sites listed. The existence of a link or organizational reference in any of the following materials should not be assumed as an endorsement by the Workgroup for Electronic Data Interchange (WEDI), or any of the individual workgroups or sub--workgroups of the WEDI Strategic National Implementation Process (WEDI SNIP). Document is for Education and Awareness Use Only ICD-10 Transition ICD-10 Milestones Whitepaper

Purpose The purpose of this document is to provide a high-level framework that organizations can use

to model or track their ICD-10 compliance efforts.

Scope The scope of this document is only to provide a high-level framework that can be used by all

types of organizations for creating work plans and tracking progress. It is not intended to provide a detailed work plan as those plans will of necessity vary for each type of organization and for each individual organization. It also is not intended to be a comprehensive list of every task needed to reach compliance. Each organization can use this framework to compare against existing plans to determine if any major items are missing or to use as a starting point to begin creating work plans. Note that the order of some tasks may vary according to specific needs, and some may be performed concurrently.

Introduction ICD-10 represents a significant impact to IT applications and business processes. Healthcare is currently facing many competing priorities, all which could affect an organization’s ability to take steps necessary to successfully transition to ICD-10. The WEDI ICD-10 Transition Sub-workgroup began working with its members to develop work products to assist in ICD-10 implementation. Although there are many good tools and documentation available through CMS as well as from other industry organizations, and vendors, the WEDI Sub-workgroup felt it was important to provide a high-level guidance document that can serve as a framework for developing specific work plans or be used as a reference tool to help determine if critical items might be missing from one’s work plans.

Organization of this document The document is organized into sections according to high level activities that are common to most organizations and listed in chronological order as follows: • Plan, Organize & Assess • Communication & Outreach • Remediation • Testing • Training • Transition ICD-10 Transition ICD-10 Milestones Whitepaper

Within each section are a series of questions that should be asked to determine if an organization has completed necessary activities. It also contains risk and mitigation measures associated with each activity.

Plan, Organize & Assess The first step in preparing for ICD-10 is to assign the task to someone who would be responsible for overseeing the effort and who can review how to pursue each of the specific steps that will need to be done within the organization. Without a comprehensive impact assessment it will be difficult if not impossible to define the overall work effort, create meaningful work plans and provide the needed resources for this effort.

Achievement Criteria -10 team?

developed a project plan with tasks and assignments?

-10 regulations/guidance?

completed an inventory of all processes, applications, documents, etc.? -10?

completed a list of the most frequently used ICD-9 codes and identified the ICD-10 codes relevant to your organization?

Obstacles

-in/support

elayed start

How to overcome them –

organizations taking action to move forward on CMS efforts

ICD-10 Transition ICD-10 Milestones Whitepaper

-cost resources

available from the government and private sectors ation improvement (CDI) outside of ICD-10, like improved reporting

of quality measures, a more complete patient record, and improved transitions of care

Communication & Outreach Because ICD-10 is an industry wide effort and not just an internal initiative it is essential that collaboration and communication among external entities also occurs. Better communication with vendors and trading partner organizations will provide a better understanding of the readiness with these external entities and will be critical in understanding the steps needed for success or special actions that may be needed. The communication should be bi-directional.

Achievement Criteria your ICD-10 communication plan for staff and business partners?

o What do you need to tell your internal staff?

o What do you need to tell your external partners about your plans?

o What do you need to know from your external partners?

o Have you asked about trading partner contingency plans?

-10 readiness information from your top providers, payers and vendors of software/systems, clearinghouses and billing services?

des needed, timelines, available training and any associated costs?

process?

Obstacles – requires coordination

nding resources or contacts to initiate communications -10 readiness/scheduling information from trading partners

How to overcome them – ing partners or vendors to share plans and verify status. A

one-time communication may not be sufficient.


ot be able to test with your trading partners

Remediation This is where the actual change process takes place. These changes include but are not limited to items such as applications, business processes, documentation, forms, business associate functions, contracts and more. It may be possible to remediate several items concurrently, thus shortening the timeline (but not necessarily the effort.) Note that it is frequently possible to begin testing before all remediation is complete. This is especially true when there are peripheral / non-critical functions that may be given a lower priority.

Achievement Criteria

needed staff on board. Also recognize there is a learning curve and plan for additional resources to adjust for this impact.

heduled timelines for systems upgrades (PMS/EMR/coding, etc.), testing and integration

with your vendors? -10?

ve you implemented training and processes to improve clinical documentation necessary for ICD-10

readiness?

mpleted a review of trading partner agreements and contracts?

clearinghouses perform edits on your behalf? Do business associate agreements need updates?

Obstacles



your efforts; identify non-critical items

Testing As remediation nears completion, changes will need to be tested both internally and externally. Testing should be as comprehensive as possible giving consideration to time, risks, trading partner availability, criticality of payer and clinical scenarios.


-10 across internal policies, processes, workflows and systems, including code assignment and usage?

support?

o perform critical testing?

-to-end testing of all transactions using ICD-10 codes?

ntify DRG shift, or changes in payment, pends or denial codes etc.?

organization can absorb during the transition period?

esting? Regression testing must assure ICD-10 changes do not negatively impact existing logic and that subsequent changes don’t impact ICD-10 remediation.

Obstacles

-9 and ICD-10 concurrently

-going production changes


testing schedule

-to-end testing ICD-10 Transition ICD-10 Milestones Whitepaper

-based

testing, portal testing etc.

Lock down testing partners early

-10 regression testing in your production changes

Training Many staff, both clinically and administratively oriented may need some form of ICD-10 training. Some may need training much earlier in the process in order to perform critical impact assessment and remediation activities. Staff not directly involved in these activities will still need training in preparation for testing and production. Timing of training is an art – it should not be completed so early that the information is forgotten, but done early enough to allow some practice using ICD-10 prior to production.


This may be on ICD-10 itself or on associated changes or concepts of ICD-10.

-10 documentation and coding education to anyone who now works with ICD-9 (e.g. physicians, billers, or medical coders, case managers etc.)?

-9 and ICD-10?

-house staff can perform training or whether outside trainers would be needed?

Obstacles

ctive training


-10 code set practice and proficiency

staff-appropriate training materials in the industry including CMS and WEDI sites.


Transition Although remediating applications and business processes and testing are highly critical accomplishments, completing these steps does not necessarily mean an organization is ready for transition to ICD-10. Additional planning may still be needed to prepare for the actual cutover and to implement measures to quickly identify potential issues and to resolve them. Most critically, organizations will need to establish some type of rollover and response plan and be ready to act if issues occur.


-10 preparation checklist for full compliance?

-live tasks and associated actions?

in the event there are problems with moving to production (trading partners not ready, production metrics indicate issues, etc.)?

d initiate response team action?

-9 and ICD-10 based on date of service or date of discharge?

volume codes/code categories?

-Implementation audit processes and procedures? This includes processes to examine the success of clinical coding accuracy, specificity and revenue neutrality.

Obstacles

-10 ready system not delivered on time


Validate your critical metrics to highlight processing variances


Conclusions ICD-10 requires a significant amount of effort across the industry and within individual organizations to incorporate all the needed changes, thoroughly test them and implement them. It is essential that organizations treat ICD-10 as a critical business priority and communicate with each other to share essential information and to coordinate activities. The effort needed up front will pay dividends on the back side with fewer issues, a smoother transition and quite possibly enhanced business processes. Slowing down or minimizing compliance efforts is a high-risk decision. Each organization will need to make decisions on things such as: How fast is fast enough?

How much testing is enough?

How many ‘surprises’ can the organization live with? Although ICD-10 may be thought of by some as a distraction from key business functions such as caring for patients or paying for care, it must be recognized that ICD-10 compliance will be necessary in order to continue doing these things. In addition ICD-10 can help enhance how these critical functions are performed.

Acknowledgements The ICD-10 Transition SWG co-chairs wish to thank the following people

who led the creation of this work product:

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