William McElmurry, Senior Vice President at SoftServ Inc. shares six ways you can utilize the one year delay in ICD-10 compliance to your advantage.
Those who invested early on in ICD-10 implementation may feel a level of frustration with recently signed legislation delaying ICD-10 compliance one year to October 1, 2015, but it may be a blessing in disguise. All organizations required to implement ICD-10 can take advantage of the delay, viewing it as an opportunity to re-assess their organization’s implementation progress and readiness. With the delay affirmed, now is the time to step back, relax some of your implementation activities and leverage the extra time you’re afforded to ensure success in your organization’s cutover to ICD-10.
Here are six ways you can use the one year delay in ICD-10 compliance to your advantage:
1. Leverage the Delayed Compliance Date to Mitigate Risk to Your Organization
All technological implementations involving a cutover from one active system to another have operational risks. Testing and training are practices contrived to manage these risks. However, both are outcomes of project planning activities. As such, the first thing you want to do when afforded extra time in a strategic implementation (such as the move from ICD-9 to ICD-10) is to invest more time in the planning phase of the project.
There’s a tendency to halt activities when an implementation date is delayed — shifting resources and attention to other programs and initiatives. It’s a mistake to lose momentum in a project already underway instead of using the extra time to better prepare and consider contingencies. A best practice is to take advantage of the delay to re-assess every aspect of your implementation plan in an effort to mitigate risk to your organization in complying with ICD-10.
It’s important not to let your implementation team disengage. Continue to meet on a routine basis and raise tasks to review all project deliverables and dependencies. Test the decisions you’ve already made regarding order of activities, scope and scale. You may find elements of your plan were artificially limited due to the older implementation schedule. Related, look for activities you may have decided to forego due to previous project timelines. Create a new project timeline based on the revised compliance date.
This task alone may be the most valuable activity you can undertake during the compliance delay.
2. Revise Your Training Plan to Maximize Staff Preparedness
The move from ICD-9 to ICD-10 promises to affect numerous procedures throughout a practice and hospital. Your team’s level of preparedness on the compliance date is directly related to a successful implementation. You want the cutover from one system to another to be seamless, ideally with no negative effect to daily operations.
Given the extra time to comply with ICD-10, you ought to review two aspects of training and staff preparedness: schedule and scope. Both may need to be addressed, the latter being an opportunity.
If you were well into your implementation when the ICD-10 compliance delay was announced, it’s likely you had begun a level of training or are nearing training dates established in your original implementation plan. If so, you need to revisit your training schedule — you don’t want large lapses in time between training and the employment of new knowledge in your organization. The longer the time between staff training and compliance, the greater the opportunity to lose the full benefit of training.
People are prone to forget elements of training, if not exercised soon after new knowledge is gained. As noted in an article published in Trading Zone, citing the study on memory curves by Herman Ebbinghaus, up to 80% of knowledge may be lost one month following training, if that training isn’t reinforced in the same period (http://www.trainingzone.co.uk/topic/forgetting-curve-and-its-implications-training-delivery/162373.
The second area of education to examine is the scope of training defined in your original plan. Especially if you’ve already begun training, you are now afforded a new starting point to expand upon. This may mean staff can train at a deeper level or advanced training opportunities may be available.
As with all strategic technology and process changes, your staff’s preparedness is the key to success. Use the extra time you’re afforded to expand your training and readiness programs: documentation training for clinical staff, code training for support staff who routinely work with codes, and overview training for administrative personnel. Training is a necessary part of readiness, so be sure not to undervalue or underestimate its importance to your success.
3. Review and Revise Your Financial Plan
Beyond the costs of upgrading technology and systems in your organization, a legitimate concern of ICD-10 compliance is the potential for a disruption in daily operations and an associated negative impact on revenue. Whether it’s losses due to DRG shifts, accounts receivable delays or loss of revenue due to decreased coding productivity, it’s a concern that must be accounted for in your plan.
Many of these risks are related to staff training and familiarity with new codes, systems and processes. As such, any impact to your organization in this area should self-correct with time. That said, a loss of revenue is potentially harmful, especially to smaller practices and hospitals.
The delayed compliance is a great opportunity to strengthen your organization’s cash position and test your financial assumptions. You need the ability to maintain a healthy cash flow in your practice regardless of unforeseen glitches in implementation and post-compliance activities. Related, the ICD-10 compliance delay may require delays in other expenditures, planned well beyond the original compliance date. You may need to forego discretionary or non-essential expenses to further build or maintain a cash reserve, such as facility improvements, lesser needed technology upgrades, marketing programs and repairs and maintenance. This highlights the need to review and revise your financial plan to make sure you can maintain a healthy cash flow throughout your ICD-10 implementation.
4. Expand Internal and External Testing
As training readies staff for ICD-10 compliance, testing readies the technical infrastructure and systems you’re employing to comply. Ideally, testing is done in an operational environment, where systems are tested not only for their technical functionality, but how they fit within staff work environments and processes.
With a one year delay in compliance, there may be opportunities to expand planned testing activities. As often happens in compressed implementation schedules, you may find critical areas of testing and commissioning are well defined, but valuable secondary and tertiary tests may have been left out of the original plan as insufficient time was allowed.
Environmental testing, both internal and external, may be an area of expansion that provides greater assurance of program success. Internal testing may include mirroring existing systems. External testing may include interfacing with clearinghouses as part of their test exchange programs to test the ability to submit claims in a simulated environment. An example to underline the need for testing in a user environment is the recent implementation of the federal government’s Affordable Care Act website, where multiple vendors blamed a lack of end-to-end testing on the failed implementation. Simply stated, each element of the overall solution tested satisfactorily, but the lack of integrated testing in a user environment resulted in the launch of a website and application unable to support its customers (http://cnn.com/2013/10/24/politics/congress-obamacare-website/).
5. Reevaluate Known Future Projects for Potential Conflicts and New Opportunities
While there can be many positives to delaying a project one year, there are potential downsides. One such area of caution is the delay’s effect on other initiatives and plans. Projects currently scheduled one or more years from now may need to be reconsidered to ensure everything from financial means and management, to human and technical resource capacity and availability.
The key is to evaluate all known future plans and activities beyond the original ICD-10 compliance date. Look for conflicts with your new implementation schedule and any financial considerations that may require delays in other projects. You want to make sure the delay in ICD-10 compliance doesn’t raise risks elsewhere in your organization. For example, if you have plans to expand your practice with an emergency care facility in the summer of 2015, months following the original ICD-10 compliance date, you need to calculate the additional cost (technology, training, etc.) of including that expansion in the revised ICD-10 implementation or consider the risk to your practice in delaying the expansion to sometime following ICD-10 compliance. The scope of your ICD-10 implementation, project timeline and immediate costs need to be examined. Your financial and operational plan may not be able to support the expansion as scheduled.
On the positive side, seek opportunities to take advantage of the expanded timeline to smartly escalate other projects currently scheduled beyond the original ICD-10 compliance date. You may find the delayed compliance date creates the opportunity to implement other projects sooner than later, possible saving money, time, energy and effort.
6. Review Technology Obsolescence and Vendor Support Agreements
Related to the risk of projects delayed due to the new ICD-10 compliance date, there is a risk of technology obsolescence that must be considered. Although compliance is delayed only a year, the reality is that the legacy systems you leave in place to support ICD-10 technology, systems, and solutions must remain supported well beyond the one year delay. As all technology has a lifespan, you need to make sure the hardware, software and systems supporting your ICD-10 solution are fully supported by your vendors beyond the new compliance date.
Supporting technologies and systems longer than previously planned may lead or force you to consider alternative plans. It may be wise to expand a project now to reduce future complexities and interruptions in your organization.
When reviewing future plans, be sure to check partner and service provider agreements for any necessary modifications due to delayed ICD-10 compliance. Specific things to look for include service and support dates, as well as commitments made to other projects possibly now in conflict with your ICD-10 implementation.
The one year delay in ICD-10 compliance affords you a unique opportunity to improve your preparedness for the October 1, 2015 cutover. In particular, you have the opportunity to vet plans underway, assess their effectiveness and enhance activities as needed. Take advantage of the compliance delay to strengthen your readiness and leverage it as a means to ensure a successful implementation by focusing on tasks benefited by additional time.
Opportunities to look for include ways to expand staff education and training, as well as expand system testing to include clearinghouse test exchanges to validate your ability to submit claims. You may be able to find new training and testing opportunities once overlooked due to time constraints that are now viable due to the one year compliance delay. Upside opportunities may include technology initiatives you can escalate to complete within the one year ICD-10 compliance delay.
Be sure to review your financial readiness and associated risk in ICD-10 compliance, taking advantage of the additional time to strengthen your cash flow and prepare to absorb contingency expenses.
Lastly, communicate with your technology partners and review your new implementation plan with them as appropriate. Look for any conflicts in their product support and check for technology obsolescence in legacy support systems.
William McElmurry is an accomplished executive with over 30 years of leadership experience in many segments of the healthcare marketplace including work with providers, payers, and software solution vendors. He is an active member of the Healthcare Financial Management Association (HFMA) and the Healthcare Information and Management Systems Society (HIMSS) where he was a moderator at the World of Health IT conference. Bill currently serves as Senior Vice President and Vertical Practice Leader at SoftServe, Inc.