Wednesday, February 1, 2012

ICD-10 Project Planning for Solo Practices – Part 3

[Note: On 2/16/2012, the 10/1/2013 deadline was suspended by HHS.  Look to later posts for the new deadline-updated 3/5/2012]

In the last post on ICD-10 project planning for the solo practice, we looked at what the first few months might look like.  Today we’ll discuss the changes we need to anticipate in order manage those situations.

Learn ICD-10
Depending on your practice specialty and the number of diagnosis involved, this may be relatively easy, or more involved depending on the volume of codes you use.    

So who needs ICD-10 training?  Well, anyone who is documenting patient information or is working with charges and claims.  This means pretty much everyone in the practice needs training.  But different roles will need different training.  To account for this, the practice should survey each job function to determine what information is being dealt with related to ICD-9/ICD-10, then train to that situation.  ICD-10 requires greater knowledge of medical terminology, anatomy, pathophysiology and pharmacology.  Do your medical assistants have the necessary knowledge to properly use ICD-10?  How do you plan to assess their preparedness?  How to you plan to train them, and pay for the training?

Cross reference ICD-9 to ICD-10 codes
Every ICD-9 code currently used by the practice will need to be cross referenced to ICD-10.  A good place to start is to acquire a GEM (general equivalency mapping) document.  Of importance here is the word “equivalency”.  It is important to remember there is not a 1-to-1 relationship between ICD-9 and ICD-10 codes.  One ICD-9 code may have three or more ICD-10 equivalents, and some ICD-10 codes don’t have an ICD-9 equivalent.  The code you use will depend on the specifics of a given situation and/or the policy of a specific payer. 

You may also want to do a reimbursement mapping.  CMS provides documents which present a single recommended mapping of an ICD-10 diagnosis or procedure code to a single ICD-9-CM alternative.  This includes all ICD-10-CM/PCS codes, but not all ICD-9 codes.

For GEMs and other conversion tools, CMS provides them on their website for free.  Many private vendors also offer them for a fee.

Review forms
Any form dealing with patient information should be reviewed and updated if needed.  Billing sheets, patient history forms, referral letters, lab orders, whatever.   Do you have order forms for durable medical equipment?  Don’t forget to update those if needed.

Update software
It should go without saying that EMR and practice management software will need to be updated.  Do you have assurances from the vendor on that update?  If not, when will they provide it to you in writing?  Survey the practice for other software which may need updating.  If you have an outside billing vendor, survey them to make sure they will be up to date in time. 

Review reference materials and how-to guides
It’s common for practices to have internally created reference materials and how-to guides for employee use and training purposes.  Review those for possible changes.

In 2013, don’t throw away your ICD-9 code books.  Until all claims with ICD-9 are processed, you may need them.  And staff may continue to need them for years to come because ICD-9 codes will continue to be in the billing and medical record system.  Don’t assume a biller hired three years from now will know that 707.03 is decubitus lower back ulcer.  They may only know it as L89.44.  

Review contracts and vendors
Review payer contracts for requirements regarding ICD-10.   Any mention of ICD-10 in that malpractice insurance policy?  Has your outside billing vendor given you a written timeline for their ICD-10 conversion? 

Have you thought about ICD-10 diagnosis requirements for lab tests?  Will your lab vendor(s) provide you with that data?

What about covered diagnosis for patients?  You’ll need to be sure you know how payers handle the transition so you can update patient charts with the appropriate ICD-10 code.

Review when payers are switching to ICD-10
Non-covered entities, such as worker compensation insurers, are not required to make the switch from ICD-9.  It is anticipated most will convert to ICD-10 in order to make things easier in the long run.  But you should determine if and when those you participate with will make the transition.

Process changes
Will ICD-10 change any of your internal processes?  Don’t assume it won’t.  Again, survey the practice to determine for sure.

Budgeting for the change
The transition from ICD-9 to ICD-10 presents many opportunities to take money out of your pocket.  And for most practices there will be some economic impact.  Cost containment can be aided by actively managing the transition and reducing variables which are out of your control.  For example, what if some of your payers struggle with the transition and payment processing is slowed down?  Well, you can anticipate that by building up a reserve fund to avoid cash flow issues.

Also, consider the effect on your employee productivity.  It is widely anticipated that billers will lose efficiency for a few weeks or months as they learn to code and process claims with ICD-10.  If your biller is 10-30% less efficient, what is the impact on your practice?  Will you need to budget for overtime?

Will you be as efficient completing your encounter notes with the increased documentation requirements?  Will the biller or medical assistant need to come back to you more often and request more detail in order to support the diagnosis code?

How are you training your staff?  Self-study, online class, AAPC ICD-10 Bootcamp?  Are you going to run the office through some scenarios so everyone can practice in a coordinated way? Will you do this on a Saturday; close the office on a Friday?  Have you budgeted for this?  What about vacations during those times?

Next Steps
Hopefully I have given you some things to ponder.  This isn’t a complete list, but should spark your thought process.  Next time we’ll give further shape to these things by discussing how to manage the process and put together a timeline.

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