Initiation and Planning

The references and links below may not have been edited to include the proposed implementation date change.

Preparing now can help you avoid potential reimbursement issues. A well-organized strategic plan and management approach is critical. Your transition will require a coordinated effort that is aligned across your organization involving all disciplines.

This section includes a selection of resources for reference to help:

  • Gain perspective on the scope of the implementation
  • Assess resource needs and identify any gaps
  • Develop a solid work plan

Each section below includes links to materials published by national health care industry leaders. If you have questions or need assistance, email our ICD-10 support team.

Project Initiation

The American Health Information Management Association (AHIMA) divided the ICD-10 implementation into phases and highlighted 10 essential steps in each phase. Phase 1 concluded in early 2011. AHIMA has urged stakeholders to start working on Phase 2 immediately after completing the conversion to ANSI Version 5010. Reviewing the steps in each of the phases may be helpful in planning ahead for ICD-10-CM/PCS implementation.

Communication, Staffing and Education Strategy

Have you assembled your ICD-10 implementation team? In addition to a technical lead or project manager, you should consider a physician "champion" to provide clinical expertise and guidance. You will also need to:

  • Implement an internal communications strategy
  • Define measures to track your success
  • Develop fully integrated organizational training and awareness programs
  • Identify and prepare your staff to execute the work plan

Systems/Software Tools/Selecting Vendors/Consulting Partners

ICD-10 will impact many system applications and software tools that may have been purchased or leased from multiple health information technology vendors. It is important that the related vendors provide ICD-10 functionalities for their applications in a timely fashion. These ICD-10 capabilities must be available to support internal and external testing.

In many cases, you may need to select new software vendors to replace systems that are not being upgraded. You may also need to find a consulting resource to assist you in your implementation efforts.

Budget Development and Business Preparation

A large component of planning an organizational shift to ICD-10 is modeling your expected implementation costs, both direct and indirect, and developing a comprehensive budget.

To help quantify risks and related costs, the ICD-10 Cost Prediction Modeling Tool  is a cost prediction tool developed by the HIMSS ICD-10 Task Force. This tool allows users to customize assumptions and requirements based on organizational needs.

The Journal of AHIMA cites a survey  suggesting that ICD-10 training costs are being underestimated until the detailed analysis is completed in the budgeting process. Organizations should avoid adopting low preliminary estimates as their final budget figures. This type of discrepancy could lead to an unpleasant surprise which could identify a large gap in a facility's budget.

It is important to consider how organizational cash flow may be impacted by the ICD-10 transition.

  • The ICD-10 cash flow tips  comprises an interview with the Senior Vice President and Healthcare Product Manager at Wells Fargo, who is also the chair of the HIMSS/Medical Banking and Financial Systems Committee. This article includes claims payment solutions developed for commercial and government insurance payment markets. It also emphasizes planning for disruptions, such as rejected claims, and developing strategies to help minimize impact on your organization.
  • As a sample, view the HIMSS Budget Planning PDF Document presentation for ANSI v5010 and ICD-10.

Key Reference Information

HIMSS collaborated with more than 30 health care and IT organizations to create the HIMSS - ICD-10 Playbook  as a tool to assist providers in their transition to ICD-10.

CMS offers a wealth of information related to the activities required to support the implementation of ICD-10. The CMS website  provides an overview of the implementation, with many materials developed by CMS to help providers, payers and vendors prepare for the implementation of ICD-10. Look for the official CMS ICD-10 logo, which identifies those materials which were developed by CMS and are intended for industry use.

Executing the ICD-10 Plan

The references and links below may not have been edited to include the proposed implementation date change.

Training and Education Plan

Executing a comprehensive training and education plan will be integral to ICD-10 implementation. Industry associations indicate that role based training with different methods of education will impact effectiveness. For additional information, see the ICD-10 Task Force’s AHIMA Training and Recommendation Resources PDF Document.

Industry associations encourage health care providers to begin ICD-10 training and education well in advance of implementation. It is recommended that the level and timing of education and training be guided by ICD-10 data-user type (e.g. IT, Clinical, Coders, etc.) and level of expertise that will be required of their role (e.g. awareness of ICD-10 only, user of ICD-10 data, coder of ICD-10, etc.). The AHIMA article ICD-10-CM/PCS Transition: Planning and Preparation Checklist PDF Document supplies two figures related to training and education. The "High-Level Awareness Education" table (Figure 1) outlines the types of ICD-10 knowledge needed by organizational role type. The "Examples of Categories of Data Users Requiring ICD-10 Education" (Figure 3) identifies different user groups that should be considered for ICD-10 education.

Tips for Successful Training (April 2011)  from the Journal of AHIMA states, "Without a doubt the transition to ICD-10-CM/PCS will impact patient care and revenue. Whether that impact is positive or negative, however, comes down to the quality of the training that organizations provide their clinical and coding staff."

Change and Process Management

ICD-10 Transformation: Five Critical Risk-Mitigation Strategies PDF Document is a publication from the Health Information Management System Society (HIMSS) which explains some of the key risks to be faced in the implementation of ICD-10. For each of the well-defined risks is an equally well-defined mitigation strategy. Specific tips are provided for practices of various sizes and types as well as for health plans.

Communication Plan

Implementing a strong communication plan will help create ICD-10 awareness, set expectations, establish timelines and promote interactions across your organization. Progress reports, presentations, newsletters and other program communications will stimulate consistent program-approved messaging for internal and external stakeholders.

Consider using the Frequently Asked Questions (FAQs) PDF Document provided by the HIMSS ICD-10 Task Force as an awareness tool. Using this information may assist in proactively addressing questions in your organization such as:

  • Why are we going through the transition to ICD-10?
  • What are the projected scope, timeline and efforts associated with the ICD-10 transition?
  • What are the possible business impacts during the transition?
  • What steps can I take now to get my organization started on the path to ICD-10 compliance?
  • What are the consequences of non-compliance with HIPAA and ICD-10?

CMS has created implementation information for small hospitals, small and medium practices, and large practices which can be found on the CMS ICD-10 website . These resources provided by CMS address a wide variety of implementation topics, including a section on the Communication and Awareness Phase. The guides cover communication and awareness from initial definition to execution and lessons learned for the following:

  • Defining the project purpose
  • Defining the audience and stakeholders
  • Creating the project plan and timeline
  • Defining communication vehicles
  • Defining communication roles and responsibilities
  • Developing messaging
  • Identifying potential issues

These documents will be helpful resources during both the strategic planning and execution phases of the ICD-10 transition.

Validating ICD-10

The references and links below may not have been edited to include the proposed implementation date change.

The Testing Phase of the ICD-10 plan is critical to a successful implementation. Testing will help verify the proper use of ICD-10 processes, procedures and systems, and will help validate alignment between you and external entities (e.g., your trading partners and vendors). Testing starts with the development of a comprehensive test strategy and test plan. It is important to share these early deliverables both internally and externally to ensure low-risk, high-quality output from the testing process.

After implementing ICD-10 changes to systems, you will need to complete several types of tests. First, you may decide to complete unit testing of individual components, system testing of integrated components and performance testing of all components. Many of these tests will be similar to ones performed for other IT changes. Second, you will need to complete specific ICD-10 end-to-end testing as described in the ICD-10 Final Rule.

The ICD-10 Testing Tables in the CMS ICD-10 Implementation Guide Books  contain very detailed descriptions of the types of testing required for ICD-10. The testing tables may be found on the following pages:

  • Pages 43-46, Table 14 – Implementation Guide for Small and Medium Practices
  • Pages 41-45, Table 14 – Implementation Guide for Large Practices
  • Pages 54-56, Table 19 – Implementation Guide for Small Hospitals

External Testing

Another important part of testing is to help ensure that all of the changes you have made will work with the partners with whom you interact. In order to test you need an open dialogue with your partners to coordinate how and when you can test with them.

BCBSMT intends to conduct testing well in advance of the revised implementation date as defined in the final ruling from August 2014. The approach to our testing will include participants in a controlled pilot test environment to ensure day-to-day business is not impacted. The benefits you will receive from participating in testing with us are:

  • A controlled test environment may help you identify process and system issues before your revenue is at risk
  • Refine and revise business flows to maximize efficiency
  • Allow for early benchmarking of performance data
  • Help anticipate coding delays
  • Possibly avoid disruption of cash flow
  • For facilities, understanding potential impacts to payments and allowed amounts, especially to payment methodologies such as Diagnosis Related Grouping (DRG)
  • Dedicated team to assist with key activities during the testing, including on-boarding

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