With the passing of Bill 4302 by the United States House of Representatives, the Senate, and the confirmation by President Obama on April 1, 2014, the deadline for ICD-10 compliance is pushed back another year. How is your organization planning for the delay of the ICD-10 compliance date to October 1, 2015? Across the United States, healthcare provider organizations, payers, and vendors were actively preparing for the ICD-10 compliance date of October 1, 2014 when the industry was taken by surprise in late March 2014 with the notification that the delay of ICD-10 would be signed into effect by the President. Many healthcare provider and payer organizations were in the midst of their Payer Testing and other preparedness activities for the transition on October 1, 2014. They were ready! Now healthcare organizations find themselves in a position to assess their current state of ICD-10 readiness and determine their action plan for the ICD-10 delay. In the industry there are several options on the table for the ICD-10 delay.
- Proceed with the organization’s ICD-10 program with an extended timeline and transition to ICD-10 on October 1, 2015
- Proceed with the organization’s ICD-10 program in a scaled down manner, ramp up at a determined time in 2015, and transition to ICD-10 on October 1, 2015.
- Pause the organization’s ICD-10 program, resume at a determined time in 2015, and transition to ICD-10 on October 1, 2015
- Consider implementing ICD-10 on October 1, 2014 and for billing purposes backwards map to ICD-9 until the revised ICD-10 transition on October 1, 2015.
- Other options as defined
Before an organization can determine their ICD-10 delay option, they need to assess the various components of the ICD-10 Program. These components, impacts, and considerations are listed in the table below. [table]ICD-10 Program Component,Area,Impacts and Considerations Governance and Program Team,Process,”Continue, Scale Down, Pause & Resume” Program and Work Group Meetings,Process,”Continue or Pause & Resume” Budget,Process,”Re-forecast to extend beyond 2014 Continue, Scale Down, Pause & Resume – what is your program’s run rate per month? What can your organization afford?” Financial Impact Analysis,Process,Continue your ICD-10 impact analysis and reimbursement impacts? Readiness,Process,”Continue readiness preparation for forms, job descriptions, procedures & policies” Clinical Documentation Improvement (CDI) Program,Process,”Continue, Begin, or Pause & Resume” Computer Assisted Coding (CAC) Implementation,Process & Technology,”Continue, Begin, or Pause & Resume” Dual Coding,Process,”Continue, Begin, or Pause & Resume” IT Systems Remediation,Technology,Continue or Pause & Resume IT Reports Remediation,Technology,Continue or Pause & Resume “Training – Clinical Documentation Specialists,Coders, & Revenue Cycle Specialists”,People,Continue or Pause & Resume Payer Testing,Process & Technology,Continue or Pause & Resume Training – Physicians & Providers,People,Continue or Pause & Resume Training – Overall Organization,People,Continue or Pause & Resume [/table]
The time is now for your organization to determine your path and plans for the ICD-10 delay to October 1, 2015. A few organizations have already determined their path with many of the larger integrated delivery networks (IDNs) continuing their program in full force or in a scaled down manner. The remaining organizations will be determining their path in the next few months.