“The deadlines are not changing. … Let me repeat that, the deadlines ARE NOT changing.”
Karen Trudel, then acting director of the Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services, uttered those now infamous words at the 2011 American Health Information Management Association’s ICD-10 Summit. Many of us, myself included, took that message as gospel and repeated it often to our leadership teams, our physicians and our boards. Based upon this certainty, we upgraded systems, prepared training programs, created clinical documentation improvement programs, and dedicated precious dollars to meeting this immovable deadline — flipping the switch on Oct. 1, 2013, from ICD-9 to ICD-10. Well, we all know how that turned out.
Fast forward to October 2014. Many organizations have slowed down, if not completely stopped, their ICD-10 preparations. When someone brings up the topic and asks when we plan to reinvigorate our efforts, the anemic enthusiasm is palpable. Based on the last experience, ongoing resistance by the American Medical Association and the lack of significantly confident messaging from Health & Human Services and CMS, it is hard to convince key constituents that, once again, we need to ramp up significant monetary and human resources to address ICD-10. It is hard to overcome the doubt.
The question on any given day is: “Will it really happen this time?” I am not the confident proponent I was two years ago. I hedge, I mumble and wind up with a “Who knows?” reply. Everyone has an opinion. It is interesting that while the AMA continues to advocate against IDC-10, it does offer information and planning tools on its website. So while the doubt continues, it is important to remember and clearly point out the potential consequences of not being ready.
So, how do you manage the organizational doubt and reticence to gear up for another nonevent? First, on July 31, 2014, HHS released a final rule confirming the new ICD-10 implementation date — Oct. 1, 2015 — and waived the traditional comment period. Second, even the most skeptical hospital administrator understands the potential financial disaster poor ICD-10 readiness will bring. The anticipated financial consequences, even with proper training and testing, have been well-documented. The coding learning curve, potential coding errors and payer inability to process ICD-10 codes alone will slow down the billing process, increase processing times, increase reimbursement denials and drive up accounts receivable days.
Now, less than a year from the deadline, many are asking about managing the doubt and anticipating the next go or no-go announcement. I contend that it is not about managing the doubt, but managing the potential disruption to your organization, to patient care and to financial viability. While there are a number of activities that are only valuable should ICD-10 really happen, including ICD-10 training, special IT system upgrades and acknowledgement, and end-to-end testing with CMS, there are many activities organizations can undertake that bring value at any time.
Regardless of the next ICD-10 outcome, there are a number of things all organizations should do anyway. These activities include:
Managing the doubt will continue to be an uphill battle. I would recommend we alter the popular “Trust, but verify” a bit and go with “Doubt, but prepare.”
Linda Reed, R.N., is vice president, behavioral and integrative medicine, and chief information officer at Atlantic Health, a five-hospital health system based in Morristown, N.J.