Healthcare ICD-10: Understanding the New System

1. Introduction and Overview to ICD-10:
Introducer: TBA,
Speaker: Mike Koehler

• (Introduce Mike Koehler and Harry Nelson and give a definition to ICD-10 and how it differs from ICD-9.) ICD-10 (the International Coding Disease version 10) is a medical classification system that is used for coding of diseases, signs and symptoms, abnormal findings, social circumstances, and causes for diseases or injuries. The latest WHO-released version, ICD-10, differs greatly from the previous version currently being used in the United States. Healthcare organizations are being required to transition from ICD-9 to ICD-10 in the near future.

2. ICD-9 to ICD-10: What Changes? 
Speaker: Mike Koehler

• This transition encompasses moving from 5 digit numeric codes to 7 digit alphanumeric codes with embedded logic in the new code structure and a different decision tree. There are approximately 8 times more ICD-10 codes than ICD-9 codes (16,000 ICD-9 codes and 155,000 ICD-10 codes). This coding system transition will touch most operational and IT processes and dramatically influence data and financial reporting strategies. Because of the scope of the transition (across all of healthcare) and the added layers of complexity, the transition for healthcare organizations is a complex, time-consuming and expensive compliance challenge.

3. Putting the ICD-10 Transition in Perspective: 
Speaker: Harry Nelson

• Despite critics decrying the ICD-10 transition as catch up (the UK shifted to ICD-10 in ’95; China did so in ’02), in fact, the ICD-10 transition represents the next major step forward in the Health Information Technology revolution: after EHR and data exchange, ICD-10 represents the first wave of the transition to putting newly available and usable health data to work. While the near-term impact of ICD-10 is in coding and revenue cycle processing, ICD-10 has an important potential role in advancing the strategic use using health data for clinical (quality) measurement and improvement and the future reimbursement landscape (value-based purchasing, pay-for-performance) purposes.

4. The growing gap between the “Healthcare Have’s and Have-Not’s”: 
Speaker: Harry Nelson

• The delay in the October 2013 deadline highlights a critical disconnect: for large healthcare providers (who have already taken the prerequisite steps, e.g. EHR, adoption of the HIPAA 5010 standards and were in the thick of the ICD-10 planning process), the delay throws a wrench into scheduling their ongoing preparation; on the other hand, for small and mid-sized providers (who are lagging badly on now overdue 5010, meaningful use, etc. and had barely begun thinking about ICD-10), delay represents more breathing room. It is unclear if or how CMS will navigate this growing gap and how much the broader healthcare information technology transformation will be further impacted by delay.

5. How to deal with delay? 
Speaker: Harry Nelson

• Despite the delay, all providers should be putting an implementation process in place. Until a new deadline is set, it will be a challenge because it is unclear when the necessary IT resources, training, and readiness expenditures will be needed. At a minimum, large providers should have an ICD-10 committee meeting periodically, resetting time schedules, and ensuring that the necessary and allocated resources are not consumed by competing needs. For small providers, it is critical to identify collaboration partners and to assign a point person (or if possible a committee) to manage the ICD-10 process.

6. Potential for Error 
Speaker: Harry Nelson

• Many people are nervous that ICD-10 will lead to serious delays in provider reimbursement. Although it will represent a significant overhaul in the payment and claims process with the potential for challenges, if history is any guide, the “doomsday” concerns about the reimbursement implications of ICD-10 are likely being overstated.

7. The ICD-10 “Prize”—Leveraging Data for Strategic Purposes: 
Speaker: Harry Nelson

• For payors and the minority of the largest providers who have the capital to harness its potential, ICD-10 will ultimately be a tool to drive quality improvement via care/disease management, utilization management, and the transition to value-based purchasing and P4P (performance measurement). Small and mid-sized providers are likely to find the burden of becoming ICD-10 compliant to be a sufficient challenge without the capital to leverage the data. If providers fail to map out a strategy to leverage ICD-10 for strategic purposes, they are likely to bear the brunt of its impact on the fraud and abuse and overpayment auditing enforcement landscape.

8. Technology Impact – Clinical Workflows: 
Speaker: Mike Koehler

• When considering the risks of the ICD-10 transition, leaders at most organizations can see what effect ICD-10 might have on their coding policies, reimbursement rates, A/R, etc. One of the things that is easily overlooked is ICD-10’s impact on technology, both directly and indirectly. ICD-10 has an immediate impact on how clinicians record and capture both documentation and orders using any electronic system. There will be a new layer of detail (complexity) clinicians need to be aware of and comply with in order for the medical records staff to code appropriately. This in turn allows for billing to be accurate and succinct. It is important that clinicians, clinical workflows, and integrated process flows are all considered when planning for the ICD-10 transition. What elements of clinical workflow will need to change? For whom will they need to change? What will different clinicians need to do differently?

9. Technology Impact – Data Warehousing and Data Integrity: 
Speaker: Mike Koehler

• Along with the added layer of complexity, as Harry mentioned, comes the added responsibility to drive more thorough reporting in the realm of quality improvement, utilization management, and other P4P (pay for performance) metrics. In addition to that, there will simply be more complex data— and more data for that matter— that needs to be stored and processed in a data warehouse. It may be the case that a given hospital’s current data integrity strategy or data warehouse isn’t geared to handle the extra data load for ICD-10. With the advantage of being able to track data with increasing levels of diagnostic granularity comes the need to store that data in a more meaningful way and to be able to retrieve it in at least the same amount of the time and in the same manner as before. If healthcare providers and payers are not able to do that, they will struggle to maintain the same level of reporting and data infrastructure quality. In addition to increased challenges with data warehousing, there’s the increased challenge of data integrity across all of a healthcare provider’s applications. Will the EMR be ready for ICD-10? Will the billing system? How about scheduling or registration? Ancillary systems such as lab or radiology? All these systems will have to be ICD-10 compliant.

10. The Key Take Away: 
Speaker: Harry Nelson

• For better or worse, ICD-10 represents a big step forward and acceleration in the ongoing transition a “data-mapped” and “data-mined” world of healthcare fraud enforcement where detection of issues happens faster and faster and investigation of providers is more and more widespread. ICD-10 will translate into significantly more audits and investigations for incomplete documentation and coding errors, and will make the last decade of fraud and abuse enforcement (where these issues were hard for Medicare and private payors to scrutinize on a widespread basis) look like a relative cakewalk. Ultimately, ICD-10 will advance the long-term flip from a post-payment review process to a pre-payment systemic use of predictive analytics by payors. Providers need to be working NOW on compliance planning and documentation to be ready for this new environment.

Speaker: Mike Koehler

• Although ICD-10 will increase the level of documentation or charging complexity for many clinicians, it will allow for more robust reporting capabilities. These reporting capabilities can help drive improved public health initiatives, quality investigations, financial analytics, and more. It’s important that as healthcare providers move towards digitized systems (due to Meaningful Use) that they remain open to embracing ICD-10 in their enterprise-wide technology strategy.