Many of you have likely read or heard this week that the acting CMS Administrator, Marilyn Tavenner, announced to the press following an AMA Advocacy Conference that CMS will “re-examine the timeframe” through a rulemaking process. She did not say when that rulemaking process will begin but said that CMS would send details about the process in the coming days.
While many will issue a sigh of relief, there is a lot still to learn still about this and what CMS will propose and when. ICD-10, as you know, is at the core of many healthcare reform efforts, and is not just a “change in coding”.
American Health Information Management Association (AHIMA) VP for Advocacy Dan Rode recently stated, “The move to ICD-10-CM/PCS is at the foundation of healthcare information changes underway in the United States. Without ICD-10 data, there will be serious gaps in our ability to extract important patient health information that will give physicians and the healthcare industry measures for quality of care, provide important public health surveillance, support modern-day research, and move to a payment system based on quality and outcomes.” I agree, and while the transition to ICD-10 is seen as a burden by many, it is truly one of the core components to enabling healthcare reform by creating much better and more specific information about the delivery of care and associated outcomes.
The completion of ICD-10 Gap Analyses, Assessments and Migration Plans remains a critical and important activity for healthcare systems and providers to engage in now, not later. Assessment allows you to finally “know what you don’t know”; Planning allows for you to prepare for and execute with confidence in order to meet the deadlines with a reasonable expectation around driving all the change.
Actually, an extension by CMS of the October 2013 compliance deadline to a later date can be seen as a strategic advantage for organizations, and not just a bonus lag of time, but only if they move quickly today.
Some of those advantages are:
1) Acquiring additional time for effective change in Physician Documentation practices and associated education around it (we know this takes time) and this provides potential financial return in ICD-9’s world too, given that better clinical documentation often directly impacts case mix index and ultimately can enhance reimbursement;
2) Certain expenses for various projects and initiatives tied to the migration (capital and/or operating) can possibly be stretched out over a longer period of time, allowing for a more gradual expenditure hopefully causing less disruptive cash impacts in support of the migration program;
3) Many organizations are still evaluating and selecting computer assisted coding (CAC) technologies to offset coding productivity impacts. More time allows for better due diligence on the vendor/technology selection as well as more time for the coding department to go thru the training, implementation and changes necessary to optimize the use of the tools. The resulting increase in productivity in today’s world a potential benefit, possibly eliminating overtime, backlogs, DNFB issues, etc. and the preparation for transition to ICD-10 and it’s productivity impacts achieved earlier.
So it remains to be seen as to exactly what CMS will tell us in the coming days and what the re-examination will bring. This could truly be beneficial in many ways, for many stakeholders as the entire industry is impacted and touched throughout with this transition. My question is, can we truly take advantage of all of the opportunities this may give us?
About Doug Hires:
Doug brings over 25 years experience in the information technology and healthcare industries, including 10 years at First Consulting Group where he served clients in the Healthcare Provider and Health Plan Sectors. During his career Doug has delivered professional and IT products and services, spanning hardware, software, networks, process redesign and implementation. Most recently, Doug served in a number of senior positions with 3M Health Information Systems, Inc., where he led a national team that delivers software and consulting services solutions for coding, transcription, speech recognition, clinical documentation improvement, document management, quality, and revenue cycle management. As a Vice President with First Consulting Group, Inc. Doug was corporate executive liaison to industry organizations, including: College of Healthcare Information Management Executives (CHIME), Health Insights (National Healthcare CEO Forum), The Scottsdale Institute (IT Leadership and Transformation in Healthcare), and The Academy CFO Forum (National Healthcare CFO Collaborative).
About Santa Rosa Consulting:
Santa Rosa Consulting is a National provider of information technology and management consulting services to the healthcare industry. Our unique culture, flagship leadership and investment in technology have uniquely positioned us to be the easiest company to do business with and the best company to work for thus Redefining the Approach to Healthcare Consulting. Primary service offerings include:
- Advisory & Consulting Services
- HIPAA X12 5010 and ICD-10
- Vendor Implementation & Integration Services
- MEDITECH Services
- Staffing & Recruiting Services