EHR and Health IT Consulting
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EHR and Health IT Consulting
Technical Doctor's insights and information collated from various sources on EHR selection, EHR implementation, EMR relevance for providers and decision makers
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Reigniting ICD-10 Momentum in Your Organization

Reigniting ICD-10 Momentum in Your Organization | EHR and Health IT Consulting | Scoop.it

Now that Congress has rejected requests to delay ICD-10, it’s time to get on the bandwagon or risk significant financial implications. ICD-10 touches virtually every aspect of your organization’s processes and systems, and failure to prepare and comply with the mandate will have a significant impact on your reimbursements.

If your organization has lost momentum or has not started the ICD-10 journey, hiring internal resources or working with external experts will be necessary to meet the deadline. Below is a cheat sheet – based on best practices and industry guidelines – of essential questions to ask leadership and next steps:

  • Is ICD-10 a priority for your leadership team?
    Evaluate organizational awareness of ICD-10 and confirm leadership is in place to drive the transition. Successful ICD-10 planning involves defining project leadership, executive sponsorship, and reporting structures. Given the far-reaching organizational impacts of ICD-10, without defined roles and responsibilities, a critical remediation area may be missed. Identify stakeholder accountability for ICD-10 compliance and designate project managers to lead revenue cycle, coding and clinical documentation improvement (CDI), and IT system initiatives. Develop a project communication plan that sets expectations about what should be communicated to whom, the reason for the communication, frequency, and method.
  • Are your systems ready and have you evaluated the impact of ICD-10 to all system workflows?
    Assess operational readiness by taking an enterprise-wide systems and process inventory to identify where codes are used. Utilize assigned project managers to uncover all systems and processes where ICD-9 codes are sent, received, or stored. Conduct workflow analyses to ensure understanding of how systems and processes are impacted. This exercise can provide immediate benefit to an organization as workflows operating inefficiently are identified. Develop a prioritized project plan and remediation timeline for each impacted area. For example, technology and workflows need to be optimized within patient access to assure compliant orders for dates of service on or after October 1, 2015. Conduct regular reporting on initiatives and ensure stakeholders are being held accountable for designated tasks.
  • Does your staff have appropriate organizational awareness and knowledge of ICD-10?
    Understand what roles individuals play within your organization with respect to ICD-9 code usage, and employ a role-based training initiative. While coders, CDI specialists, and providers will need the majority of training, areas, such as patient access, ancillary departments, business offices, and IT should not be overlooked. Also, keep in mind the impact on your quality team. Patient populations monitored by core measures, as well as other quality metrics are determined by ICD-9 codes. When selecting a training vendor, confirm the vendor offers courses tailored by job function and provides the necessary courses for coders and specialty-specific training for providers. Track and communicate training progress and ensure training compliance is an organizational priority. As part of your strategy, attempt to incorporate training with other planned education to reduce workflow disruption.
  • Are you establishing ongoing experience with the new code set?
    Act fast to incorporate dual coding initiatives. Based on experiences with ICD-10 in other countries, research suggests that allowing coders to simultaneously code in ICD-9 and ICD-10 allows them to achieve proficiency and decrease productivity loss. Dual coding has been shown to significantly reduce the anticipated 40 to 60 percent inpatient and estimated 20 percent outpatient productivity loss. The first step is to create a project plan that identifies coders, checks systems, and determines expected coding system upgrades. Next, create a strategy for managing dual coded data to be analyzed. A coding roundtable of key stakeholders from an organization’s coding team should be developed to create accountability and drive documentation improvements during the dual coding process. As part of the learning process, coder education should initially emphasize documentation requirements for coding the most common conditions within the organization and those with the highest allowed amounts. A minimum of six months of practice is recommended.
  • Are you conducting internal and external testing of systems for ICD-10 compliance?
    Define testing goals and document a plan to test each impacted system internally and conduct external testing to the greatest extent possible. Appropriately testing impacted applications is a complex and time-consuming process and should not be seen as a last step. Many variables — including competing organizational priorities and resource availability — as well as clearinghouse, payer, and third-party tester schedules, can influence the testing timeline. Designate a well-defined team to undertake, define, and monitor the testing readiness plan for your impacted systems and software. Each impacted system should be reviewed for the type of testing that is needed. Billing systems are the most complex and must be ready to send ICD-10 coded bills to payers or payment will be denied. Testing of billing systems should include all of the workflows where codes live, (e.g., claim edits that currently contain ICD-9 codes). Use your high volume and high value codes for testing, and determine the ICD-10 workflow for each impacted application. Then, complete individual testing of applications by running the applications through the identified workflows. Once that process is complete, begin integrated testing through following the process for codes to flow to downstream applications and out to the payer. If you haven’t been selected for payer testing, then work with your clearinghouse to test claims externally through them.
  • Is your CDI program optimized and ready for ICD-10?
    Emphasize clinical documentation process improvements to realize bottom-line gains now while preparing for ICD-10. While most healthcare systems have a CDI program, many are not achieving the desired results in appropriately coding conditions to the highest level of specificity. For example, if the organization is not able to code the specific type of congestive heart failure in ICD-9, the problem will only worsen in ICD-10 with requirements for greater specificity to attain complications and co-morbidities (CCs) and major complications and co-morbidities (MCCs) for many DRGs. While revamping a CDI program is a separate goal, perfecting ICD-9 queries and introducing ICD-10 queries early will help prepare an organization for ensuring compliance with the increased specificity ICD-10 demands.
  • Have you planned for predicted delays in cash flow?
    Create a contingency plan to mitigate potential productivity and revenue losses. Hope for the best, but prepare for the worst. Based on Canada’s ICD-10 experience, coding productivity may drop by 50 percent immediately following implementation. Performance improvements may take at least 90 days to be realized. If claims are suspended, rejected, or delayed following ICD-10 implementation, have a plan available in advance to quickly respond to different scenarios. Alternatively, some providers and payers have drafted stopgap provisions in their contracts to maintain a consistent cash flow and “true up” every three months.

While changing processes, systems, technologies, and staff resources to accommodate the shift from ICD-9’s 17,000 to ICD-10’s 140,000 codes may seem overwhelming, there is still time to meet the requirements by taking a prioritized and focused approach.  Having the right mix of expertise and staffing is necessary to meet the upcoming deadline.  Contingency plans will also help mitigate losses following ICD-10 implementation. Beyond getting paid, ICD-10 also promises to improve clinical outcomes by increasing the specificity and accuracy of clinical documentation to guide patient care decision-making. It’s an investment that is worth the effort.


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HHS calls Stage 3 rule 'flexible, clearer framework' | Healthcare IT News

HHS calls Stage 3 rule 'flexible, clearer framework' | Healthcare IT News | EHR and Health IT Consulting | Scoop.it

It's more of a requisite first step than milestone, but the Department of Health and Human Services sent the proposed rule for meaningful use Stage 3 to the Office of Management and Budget.

There’s precious little detail in these submissions, but HHS foreshadowed the major problems it intends to address with this next, and perhaps final, stage of the federal EHR Incentive Program.

"Stage 3 will focus on improving health care outcomes and further advance interoperability," according to OMB’s website. "Stage 3 will also propose changes to the reporting period, timelines and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements."

The Office of the National Coordinator for Health IT also submitted a rule to OMB proposing a new 2015 Edition Base EHR definition, as well as modifications to the ONC Health IT Certification Program, "to make it more broadly applicable to other types of health IT health care settings and programs," another OMB web page states.

ONC’s proposed rule would establish capabilities and criteria, and specify standards and implementation specifications that EHR makers must meet, to "at a minimum support the achievement of meaningful use" for customers including eligible hospitals and eligible providers looking to attest and receive incentives.

OMB ranks both proposed rules as “major” but the in the form’s legal deadline field the status is none.

Stage 3 is expected to begin in 2017.


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Ingredients to a Successful ICD-10 Implementation - HITECH AnswersHITECH Answers

Ingredients to a Successful ICD-10 Implementation - HITECH AnswersHITECH Answers | EHR and Health IT Consulting | Scoop.it

Have you ever thought about just how many moving parts there are in an ICD-10 implementation? The whole process can seem overwhelming to a practice and as a Practice Management/EHR vendor who needs to understand all of these different pieces, we’ve found that the best way to approach this is by breaking down the implementation into three main ingredients: People, Processes & Technology. So what do these mean, what’s your role and how do you formulate a plan for ICD-10 success?

People – Because a successful ICD-10 implementation affects all departments in your practice, awareness, preparation, testing and training should already be well underway. Medical coders and physicians aren’t the only people who require high ICD-10 competency. The key to preparing your entire staff for ICD-10 readiness is identifying what training is required by role, who conducts the training, budgeting for training costs and downtime, timing and finally, ensuring staff is adequately prepared and capable. ICD-10 readiness should include regular communications with management, IT staff and clinical staff about new procedures and new or updated software such as Practice Management and EHR systems. Staff also needs to be able to handle new requirements and forms, such as paper superbills, as part of the new billing, claims and documentation procedures.

Processes – The impact of ICD-10 on practices can vary depending on specialty, patient mix, top diagnoses and payer mix. Solo and other small practices will typically have greater risk and deeper impacts due to fewer resources and available funds. Moving to ICD-10 will require tremendous effort and process coordination of nearly every workflow. Processes to manage 120,000 new codes in a way that allows simple, accurate look-up and application of codes requires collaboration across the practice – including your IT systems and people. Productivity standards may have to be redefined, requiring additional coding staff, existing staff may need to be retrained, and providers may need to change how they document with more detailed diagnosis information.

Technology – This is the backbone of a successful ICD-10 implementation and gives your practice, people and processes a foundation to guide your operations and improve coordination of benefits and care. When properly configured to an ICD-10 environment, technology can help ensure critical processes are performed – such as documentation, coding, billing and bi-directional data transmission – all while ensuring third-party integrations can do the same. As the ICD-10 crossover date approaches, the risk of having non-compliant IT systems grows exponentially. By paying close attention to your existing IT environment and examining it against changes required to accommodate new data, new workflows and potentially new people prior to implementation, you can greatly increase your ICD-10 readiness.

As you can see, we all have a responsibility to understand the ingredients that make up an ICD-10 implementation, which will increase our knowledge in these areas and in turn, reduce risk. Look for opportunities for training, industry webinars and vendor testing. Some vendors are even offering ICD-10 Risk Assessments to assist practices in understanding the impact of ICD-10 and providing recommended actions based on the assessment results. All of these opportunities will support the success of the People in your practice performing Processes that are supported by your Technology. When these three ingredients are understood, planned for and in sync, we’ll be able to achieve ICD-10 success together!



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Is Physician Fear of ICD-10 Turning Them Off Preparation? | EHRintelligence.com

Is Physician Fear of ICD-10 Turning Them Off Preparation? | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it

There are a lot of reasons for healthcare professionals to dislike the notion of ICD-10.  More mandates, more money, more work, and more complications that do nothing but take highly-trained physicians away from the business of patient care have been repeatedly cited as reasons why the industry should just forget the new code set all together.  But new research from AHIMA shows that frustration, empty pockets, and exhaustion may not be the only things slowing down the ICD-10 adoption process.  Many physicians in a series of focus groups expressed straight-up fear about how the new codes will impact their practices – and even more worryingly, expected their EHR vendors and billing services to do most of the heavy lifting as October 1, 2015 draws near.

“ICD-10 is scary for most people,” one physician admitted during one of the interview sessions.  The large-scale changes required to bring clinical documentation up to the appropriate level of detail and specificity are of great concern to many physicians, not only due to necessary changes in their workflow, but also because of the uncertain impact on their reimbursement.

Physicians may be jittery about the unknowns of the future, but they aren’t necessarily being proactive about addressing them.  Blaming a lack of simple educational tools, comprehensive resources, and specialty-specific guides to clinical documentation improvement (CDI), physicians in the focus groups are generally taking a wait-and-see approach to problems that may arise from documentation issues.  They will address issues as they occur and learn as they go after implementation.  They expect their EHR and billing system vendors to provide them with templates and order sets that will make documentation easier, and tend to think the biggest problems will only hit providers who perform a wide variety of procedures or see very complex patients.

“I have not done anything except read an article or two about how codes are going to increase in ICD-10,” a participant said. “I am relying on my billing service to do that. With respect to the hospital, they have not really given us any formal training for ICD-10 at all.”

“Physicians…typically don’t want to spend very much time on training for things like this,” added another. “It’s hard to engage them, so finding a set of materials that they will respond to positively would be valuable.”  Hiring an HIM or CDI professional to develop educational programs and train physicians on ICD-10 issues seemed an attractive path for some physicians, but others worried that hospitals with the resources to maintain an HIM department may only invest in significant training for inpatient coding, leaving the less lucrative outpatient coding aside.

“Hospital coding is totally depending on ICD-9 and as they convert to 10, they will do the training (for inpatient). But that is inpatient. What about outpatient? The hospital will train you as they have a vested interest. For outpatient, I don’t know,” remarked a participant.

“For surgeons, nothing came from formal groups; most of the information regarding ICD-10 preparation and training would come from the hospital side as they have the best interest in training the physicians mainly for hospital utilization and reimbursement purposes,” agreed another.

Will EHR vendors and billing partners pick up the slack?  Physicians certainly hoped so, believing that vendors would provide training and assistance if their hospitals and specialty associations didn’t give them adequate education.  The groups called ICD-10 a “new language” for them to learn, and put specialty educational materials at the top of their wish lists.  One requested “ICD-10 for dummies dumbed down by specialty,” while others asked for easy-to-understand crosswalks and a top-ten list of the most frequent reasons claims are being rejected.

The problem, many of the responses seem to indicate, is that ICD-10 isn’t meeting physicians where they are.  CDI itself is not the issue, nor is the extra burden of added time and education, even if the thought of spending a few lunch breaks or extra evenings in a specificity seminar isn’t enticing.  ICD-10 has taken on a life of its own as the big bad wolf of the healthcare industry, its shadow of trepidation growing deeper each time the new code set is delayed.  Many physicians want to view the changes as a positive development, but feel that available resources aren’t helping them do so.  “Articles on ICD-10 are fear-based,” said a participant.  “I try not to go there.”

So where will they go?  To health information management professionals, hopefully, or to CDI experts offering outsourcing services or workshop materials that will preempt the watch-and-wait attitude that may result in significant reimbursement disruptions.  It isn’t fear mongering to say that preparing in advance for ICD-10 is a wiser course of action than simply hoping that the storm will pass by without serious damage, or letting fear of the unknown preclude the search for resources that will meet a specialist’s particular needs.  ICD-10 will require effort, but the industry has been preparing for the switch for a long time, and the right training is available to those who look for it.

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Developing a Specialty-Specific Action Plan for ICD-10

Developing a Specialty-Specific Action Plan for ICD-10 | EHR and Health IT Consulting | Scoop.it

As the calendar turns over to the beginning of a new year, the healthcare industry begins yet another countdown towards an autumn implementation date for ICD-10.  With just under ten months left until the most recent deadline of October 1, 2015 – and that date likely to stick thanks to Congressional support and a growing chorus of healthcare stakeholders endorsing the switch – healthcare providers may not have the luxury of banking on an additional delay.  Organizations can make the most of their remaining time by using CMS resources to develop a specialty-specific action plan that will carry them through their ICD-10 prep for the rest of the year.

The Centers for Medicare and Medicaid Services has provided a number of transition resources to providers who may not be sure what is required for the ICD-10 switch or how to achieve transition benchmarks.  Among these Road to 10 tools is an interactive timeline feature which allows providers to select their practice type, size, progress, and business partners to formulate a personalized plan.

The action plan tool provides common specialties with tailored information, including the clinical documentation changes necessary for the most common ICD-10 codes and sample clinical scenarios for practice.  For cardiologists, for example, the literature reminds practitioners that a myocardial infarction is only considered acute for a period of four weeks after the incident in ICD-10 compared to 8 weeks in ICD-9.  Orthopedists are prompted to remember the specificity requires to accurately code a bone fracture, including the type of fracture, localization, healing status, displacement, and complications, while obstetricians will need to distinguish between pre-existing conditions and pregnancy-related issues when documenting complications.

For the 27% of providers who have not planned to start their ICD-10 testing as of November, and especially the 30% who admitted that a lack of understanding had them stalled, the Road to 10 timeline provides detailed steps to achieve internal and external testing of systems.  From identifying sample cases for testing to coordinating with external business partners and fixing any problems that arise from the process, the resource allows providers to review checklists and suggestions that will set them on their way towards a successful testing period.

CMS suggests that healthcare providers have their internal testing already completed by this point in the process, and is currently seeking volunteers for their end-to-end testing week scheduled for the end of April.  According to the timeline, the external testing process is likely to extend through July as organizations coordinate with their payers and clearinghouses, but the number of providers that are significantly behind these recommended timeframes means that many in the healthcare industry are likely to experience a sharp crunch up against the October deadline.

Providers that are struggling with the sheer volume of tasks associated with the ICD-10 switch may benefit from using the Road to 10 toolset and exploring CMS resources on the transition to identify common pitfalls that may strike their specialty or size of practice.


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The Real Problem with ICD-10 Delay or ICD-10 #NoDelay

The Real Problem with ICD-10 Delay or ICD-10 #NoDelay | EHR and Health IT Consulting | Scoop.it

Today, AHIMA put together a really interesting Twitter campaign (they called a Twitter chat, but it wasn’t as much of a chat as a Twitter campaign in my book) where they tweeted about the need for no more delay to ICD-10. You can see what they did by checking out the #nodelay and #ICD10Matters hashtags. They were hitting a number of congressmen really hard. No doubt, their social media people will have seen these messages. We’ll see if that trickles up to the senators and representatives themselves.

On the opposite side is the AMA which is pushing congress for a 2 year delay to ICD-10. Modern Healthcare just published a story that the ICD-10 delay bill was “dead on arrival.” However, that seemed like a link bait headline. When you read the actual story, they suggest that the ICD-10 bill might be dead when it comes to the lame duck session of congress (now through the end of the year). However, it doesn’t address whether congress will choose to incorporate another ICD-10 delay into the SGR fix in 2015 like they did in 2014. That story is still waiting to be played out.

The real problem with all of this is a topic that we’ve discussed over and over here on EMR and EHR. It applied to meaningful use and EHR certification and now it applies just as well to the implementation of ICD-10. No doubt there are proponents and opponents on each side of the ICD-10 debate. Personally, I’ve seen both arguments and I think both sides have an interesting case to make. I don’t think the decision is as clear cut as either sides makes it out to be. If you delay ICD-10 many organizations will be hurt. If you move forward with ICD-10 many organizations will be hurt.

Uncertainty around ICD-10 is the real problem.

What’s worse than going ahead with ICD-10? Uncertainty about whether ICD-10 is going forward or not. What’s worse than delaying ICD-10? Uncertainty about whether ICD-10 is going forward or not. ICD-10 uncertainty is costing healthcare much more than either an ICD-10 delay or a hard and fast ICD-10 go live date.

The US government (yes, that includes all parts of the US government) needs to make a firm decision on whether ICD-10 should be implemented or not. If ICD-10 is going to be the US medical coding future, then we should bite the bullet and implement ICD-10 on schedule. Another delay won’t improve that implementation. If ICD-10 is not of value, then let’s offer some certainty and do away with it completely. Either way, the certainty will be more valuable than our current state of uncertainty.

I’ll admit that I’m not an expert on DC politics. However, I’ve wondered if there’s something the US government could do that would provide this certainty. In 2014, CMS had done everything they could do to provide that certainty. It turns out, they didn’t have the power to make such a promise. Congress undercut them and they got left with egg on their face.

Could Congress pass a bill that would either set the ICD-10 implementation in stone or banish ICD-10 forever? Would that provide healthcare organizations the certainty they need to plan for ICD-10? Or would they just be afraid that the President would do some executive order to delay ICD-10 again? Is there anything that can be done to communicate a clear message on ICD-10’s future?

My gut tells me that if ICD-10 isn’t delayed in the SGR Fix bill next year, then ICD-10 will probably go forward. You’ll notice that probably was the best I could say. Can anyone offer more certainty on the future of ICD-10? I don’t think they can and that’s the problem.



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