Guest post by Michele Hibbert-Iacobacci, CMCO, CCS-P, vice president, information management and client services, Mitchell International.
The International Classification of Diseases – 10th Revision, Clinical Modification and Procedural Coding System’s (ICD-10-CM/PCS) implementation in the United States is being delayed yet again. According to the latest polls and surveys, there are many organizations (most who need to use it) that were ready to roll with the new classification on October 1st 2014. The change came about because the Senate approved a bill (H.R. 4302) on March 31, 2014, that delays the implementation of ICD-10-CM/PCS by at least one year and then a subsequent official announcement by CMS announced a forthcoming interim final rule that would set the new compliance date for October 1, 2015.
How will this new implementation date affect Property and Casualty payers and providers? For an industry that was not required to change, P&C was ready to go – mainly because of the dependency on payments and bill processing. The question was, “Will we see ICD-9 and/or ICD-10?”
Fortunately, from a processing perspective the P&C industry was prepared for most anything. Payers were creating processing systems and/or contracting with vendors who considered all possibilities including bills submitted with both codes and the submission of ICD-9 codes well after effective dates. These payers also considered the compliance environment as most are guided at the state level.
As difficult as it may be to be ready for the effective date of ICD-10 just to have it changed, most aspects are positive for property and casualty. Additional time for testing, communication to providers and overall education (external/internal) enhances the readiness for the new date. The negative is the cost – staff has been added and enhanced with testers, educators and coders for the initial date. Maintaining staffing levels for a longer period of time was not accounted for in most budgets. The cost will be higher to implement now and many companies did not plan on the additional timeline.
So how will this shake out moving forward? Providers will likely react by submitting ICD-10 codes to P&C payers before the implementation date of October 1, 2015. Payers will need to make decisions on how they will handle these claims since P&C is not guided by the same rules under HIPAA as the health side. Some payers may decide to turn these claims back to providers and others will translate to ICD-9 for payment. Compliance standards, whereby a state has implemented mandates on the use of code sets that need to be addressed and/or revisited, may also impact the way payers process ICD-10 codes prior to October 1, 2015.
Guest post by Michele Hibbert-Iacobacci, vice president, information management and client services, Mitchell International.
Employee morale is a constantly at the forefront of the healthcare industry because of on-the-job stress, do more-with-less mentalities and a consistent cost containment focus. With the introduction of ICD-10, employees who work in healthcare as medical coders will be expected to maintain productivity and produce quality coding. We are changing the communication language used between payers and providers and have an expectation that everyone speak the same language as of a specific date.
Although difficult to attempt in a short time frame, this language change has been coming for many years and we should be ready by October 1, 2015. While the industry has been given more time to prepare, this transformation will still have an effect on the medical coding professional from a morale perspective, let’s face it – do coders know ICD-9 or what? Most have ICD-9 memorized so change will be a very new condition for the medical coder to deal with.
Steps to mitigate morale issues should be reviewed and/or introduced to minimize pushback and employee attrition. Skilled coding professionals are needed in the industry, they are valuable and the ICD-10 language barrier is one that requires specific steps to maintain medical coder involvement.
Having worked as a coder for many years, I can attest to the following as ways of boosting morale:
Guest post by Michele Hibbert-Iacobacci, vice president of information management and client services, Mitchell International.
Seamlessly integrate ICD-10? How is that possible? Realistically, yes, ICD-10 is new and the United States will start to utilize the new code set effective October 1, 2014.
Is ICD-10 really new, though? Not really, and frankly many entities are so ready they are looking forward to ICD-11, which has a “who knows when” implementation timeframe.
Seamless integration of anything takes preparation. The best part of ICD-10 is that covered entities have started and stopped implementations twice prior to the impending October 1, 2014 effective date. In fact, we almost had a third postponement with proposed federal legislation called the “Costly Codes Act,” which today has a two percent chance of making it to committee and zero percent chance of passing. This bill has more than 35 sponsors, so it’s amazing that we are seven months from implementation and this type of delay is still being contemplated.
It’s likely the sponsors are not aware of where ICD-10 has been and where it is going. The 2014 implementation date was postponed because of providers not being ready for the program. A third postponement would be devastating to the entities that have prepared for all three implementation dates.
The casualty claim arena involves evaluating and payment of claims for claimants who have suffered from an auto accident or workers’ compensation injury. This side of the health payment continuum has been omitted from the Health Insurance Portability and Accountability Act (HIPAA) as a covered entity.
This means that casualty claim insurers are not required to abide by the standards set forth in HIPAA and that these standards only apply to the health payer. Omitting the ICD-10 in casualty claims from standards does have merit, but when it comes to standardization, all health claims should be adjudicated and paid in the same manner. Why should a provider charge differently and be paid differently when the payer of the claim is not on the health side? This is a question many casualty payers ask and not being part of the standardization only raises the question more.
There is no option for submission of claims by the covered entity to not be compliant by October 1, 2014 with the International Classification of Diseases, 10 Revision (ICD-10). Why is it a good idea to omit the casualty payer from these standards if the majority of health payments are made using this new standard? In addition, if providers are covered entities, then why would the casualty payer not speak the same code language? It’s almost like trying to communicate in a foreign country without the benefit of knowing the language.
Recently, the president of the National Association for Home Care & Hospice (NAHC) called on all American’s to commemorate National Home Care & Hospice Month. He also stated that in the coming years, home health care is poised to play a central role in the delivery of healthcare throughout the country. Yet, the growing home health market is not without challenges. Solutions that blend innovation and mobility at the point of care can help pave the way for strong patient-caregiver interactions and support positive outcomes.
Home Health Poses Challenges: Mobile Solutions Can Improve Care Delivery
An aging population and tough new compliance and regulatory issues are posing challenges for the home healthcare segment. The unique and specific needs of the home healthcare market must play a paramount role in organizations seeking to develop mobile solutions to address these issues. Home caregivers urgently need “smart” solutions that address not only patient privacy, but also, wireless connectivity, mobile printing, security and remote data access.
There are a number of issues and trends impacting the healthcare industry that solution providers and caregivers need to keep top-of-mind:
Reimbursements/Re-admissions – Medicare reimbursement reductions and new penalties are being imposed on hospitals with high avoidable re-admissions. This increases the pressure on home health agencies to leverage technology to aid patients in following aftercare instructions, adhering to medication plans and accessing their medical information – all to better prevent costly re-admissions from occurring.
Will your healthcare organization be ready for the Oct. 1, 2014, ICD-10 implementation date, as mandated by the Department of Health & Human Services? By now, most organizations should be in the middle of their ICD-10 implementation, or at least nearing the end of their assessment and planning.
Based on my ICD-10 industry knowledge, here are aspects of implementation your organization can expect to experience.
Where is my ICD-10 budget?
Many organizations will struggle to gain the right level of budget to make the ICD-10 transition successful. Most will likely have one budget cycle remaining, at most, before the ICD-10 go-live date. You’ll likely have to compete with other initiatives to secure funding.
However, what many organizations fail to realize is that 100 percent of their patient-related revenues are at risk if ICD-10 is not properly implemented and its risks mitigated. As a result, most organizations will not have budgeted enough for ICD-10 and did not allocate enough contingency to account for the unknowns of implementation.
Guest post by Chris Giancola, principal consultant at CSC.
Looking into what’s ahead, 2013 will be another year of compliance activities dominating the healthcare landscape. Mandates on the industry, from both the ARRA and ACA, are fully underway and stretching the financial and intellectual resources of healthcare providers and insurers across the country. Here are three major compliance pressures facing the industry this year:
ICD-10 – Though the U.S. Office of Health and Human Services delayed the ICD-10 compliance deadline to October 2014, it did so back in August 2012. This early action by HHS acknowledges the enormous scope of the challenge facing providers, HIT vendors and insurers that stands to impact every administrative process and workflow. Far beyond simply recoding claims, any process involving a diagnosis will materially change because of the higher degree of clinical specificity described by the ICD-10 code set, such as obtaining referrals and lab tests for patients, providing clinical decision support and e-prescribing.
Insurers and providers also will face the challenge of understanding how the code changes may impact their bottom line by determining the financial neutrality of any potential change in diagnoses and payment for treatment of those conditions. Providers relying on vendors with fixed or appointment-style upgrade schedules should consider as early adoption as possible to reduce the potential negative impact of these changes. There also will also be a period of overlap where both ICD-9 and ICD-10 code sets will need to be supported by all participants involved, increasing the complexity of the problems looming on the horizon.
Organizations that are late on their remediation timelines will increasingly look for solutions, like selective outsourcing and alternative technical solutions that will allow them to minimize the implementation risk and operating costs of achieving necessary compliance. But, if the ANSI X12 4010 to 5010 conversion was any indicator, these alternative solutions will be offered at a premium price.
Meaningful Use Stage 2 – Stage 2 makes much of the optional menu set of objectives in Stage 1 a part of the mandatory core set, meaning that those providers who deferred as many of the optional objectives as possible now face challenges in Stage 2 they can no longer avoid. Also, in 2014, penalties for noncompliance with Stage 2 will begin to take effect, and so 2013 will be the year for many providers to buy or build new capabilities, such as web-based and device-accessible portals to satisfy patient engagement objectives and to change clinical workflows to meet Stage 2’s objectives and gather new mandated quality measures.
In Stage 2, Eligible Physicians (EPs) must complete 17 core and three of six menu objectives for a total of 20 objectives. Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) must complete 16 core and three of six menu objectives for a total of 19 objectives. Though Medicare or Medicaid incentive payments will offset some of the financial impact of implementing electronic health records, the impact to administrative and clinical staff, as well as to previously paper-based workflows, will be nontrivial.
Payment Reform – Many providers have already felt the financial impact of changes to their contracts with insurers that are implementing alternatives to the fee-for-service reimbursement models of the past. Bundled payments to providers for disease-state management will require higher degrees of care coordination and information sharing not only within delivery systems but across disparate organizations and affiliations.
Effectively managing referral networks will be a key success factor in the coming year. New payment contracts also typically require greater degrees of reporting to the insurer to ensure that quality of care is not being compromised, further increasing the burden on providers to gather, harmonize and report on clinical data previously written on paper or buried in unstructured text.
Compliance with these mandates, though not imposed by federal or state regulations, will grow to be a larger challenge as these new payment models mature and they represent a larger portion of providers’ revenue streams.
Chris Giancola is a principal consultant at technology consulting company CSC with a combination of technical skills, project and product management experience, business development successes, and healthcare domain expertise.
