i cd 10 summit takeaways
TRANSCRIPT
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Ediecs, Inc
Key Takeaways from
the 2012 ICD-10 Summit
A Compilation of Prevailing Wisdom,
Lessons Learned, andof Coursethe
Concerns Over a Potential Delay
Publication Date: March 12, 2012
Special Report:
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Audience Poll
Yes No Uncertain
Within 3 years, do you believe that ICD-10
will drive down healthcare costs for your
organization?
42.9 %34.7 %
22.4 %
Chie Executive Ocer/Chie Operations Ocer
Chie Financial Ocer
Chie Inormation Ocer
All o the above
Other
Who is Sponsoring your ICD-10 effort?
23.9 %
2.2 %
8.7 %
13 %
52.5 %
Less than $10M More than 30M
11M20M Dont know
20M30M
What is your overall ICD-10 budget?
16.9 % 18.5 %
33.8 % 16.9 %
13.8 %
Key Takeaway #1:
The Value of ICD-10 (a.k.a. Why are we doing this?)
There is much to debate about ICD-10, including the required time and cost investments an
how it will ultimately help the industry deliver better care. Ater all, any large undertaking in
healthcare should have a meaningul impact to the system itsel.
The prevailing sentiment among Summit attendees is that while the migration to ICD-10 m
be painul, it is an important stepping-stone to getting a better grasp on runaway costs and
leveraging more granular data in support of Meaningful Use and quality measures.
Regardless o the nal decision on whether to delay the ICD-10 compliance deadline (at the
time o this report, HHS had not issued a nal decision), Summit participants expressed stron
support or ICD-10, and this was echoed by a CMS representative during the nal keynote
presentation. All believe ICD-10 will bring value to patients, providers and payers.
The key to great healthcare is in the data. The promise o ICD-10 is that the data the industry
previously couldnt collect at a granular-enough level will now be available and help take th
industry to a higher level o care.
In 2004, the RAND Corporation, in a report titled The Costs and Benefts o Moving to ICD-10 Code
Sets1, quantied some of the benets of improved data derived from ICD-10. RAND conclude
that the benets ar outweigh the costs o implementation, estimating the dollar value o th
benets in the ollowing categories:
More accurate payment for new procedures
Fewer rejected claims
Fewer fraudulent claims
Better understanding of new procedures
Improved disease management
Though the frequently cited RAND report is several years old, many in the industry still cite its nd
and the benets it outlines. At the ICD-10 Summit, CMS urther expanded upon these point
Better analysis of disease patterns and treatment outcomes this will help the industry
better track public health risks, identiy trends and share best practices o care
Specicity and accuracy of health data this forms the foundation for eective
research and supports disease management and decision support tools Robust categories to support quality measurement eorts this will better inform
policy decisions to improve health outcomes
While time will tell who actually will benet from ICD-10 and to what degree, the various
Summit presenters, including CMS, broke it down in more detail throughout the two days.
Value to Payers: An overarching goal or many health plans is to ensure they and the memb
they cover are paying the right amount or the right care, delivered at the right time. ICD-10
deliver on this goal via:
Improved administrative eciencies only one in ve medical claims are paid without requ
or additional inormation. According to the nal rule or ICD-10 published by HHS in 20
a reduction in rejected claims as a result o ICD-10 could save the industry $578 million
Enablement of more precise rate setting for medical services Better support for comparative eectiveness research to identify best practices and info
standards o care
Support for Aordable Care Act (ACA) initiatives, particularly in the areas of fraud, waste
and abuse
Support for the move from the current volume-based healthcare delivery system to a
value-based purchasing system that focuses on quality of care and health outcomes ve
the volume o patients and procedures
1RAND Corporation. The Costs and Benefts o Moving to ICD-10 Code Sets. March 2004.2U.S. Department o Health and Human Services. Federal Register, Vol. 74, No. 11. HIPAA Administrative Simplif
tion: Modifcations to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS. January 16, 2009.
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Yes No Uncertain
For those companies targeting
neutrality, have you framed/dened
your neutrality process?
16 %
51 %
33 %
Yes No Uncertain
Will ICD-10 granularity support
improvements to quality efforts that
are designed to improve outcomes?
83.6 %
14.6 %1.8 %
Audience Poll Value to Healthcare Consumers: Patients want to trust that their providers and insurancecompanies are providing the best medical decisions and treatments at the right cost. They a
seek to have care tailored to their specic condition (known as personalized medicine) to
ensure optimal treatment. ICD-10 can help achieve these goals as well, because:
ICD codes drive clinical decision support software. When coupled with the use of
electronic medical records and healthcare inormation exchanges, patients can avoid
undergoing and paying or re-diagnosing or re-testing, unless there is a demonstrable
need. The black hole o inormation will no longer exist In healthcare, specicity and accuracy matter. Accurate data and better technology
will save lives
More detailed data and clinical evidence can drive development of more targeted,
powerul and robust disease management protocols
Value to Providers: ICD-10 will ease meeting other healthcare mandates, including
requirements for Meaningful Use, because it enables more expansive and granular reporting
o medical diagnosis and inpatient procedures. Because ICD-10 promises to yield more
specic data, tying it to EHRs now, rather than later, is benecial to payers, providers, and
patients. More specic data can be more eectively analyzed to create better health
outcomes, or example:
A huge concern is how to classify the patient who fails to follow a recommended
regimen o care and gets sicker as a result. ICD-9 has only one code or patient
non-compliance. However, in ICD-10, there are at least eight, including Intentional
under-dosing due to nancial hardship and Unintentional under-dosing due to
age-related debility. By documenting a more specic reason or non-compliance,
providers can tailor ollow-up care to improve the patients health outcome
ICD-10 will also help reduce time spent on rejected claims (as well as time needed
to request and process additional supporting clinical documentation). The ICD-10
codes already provide more detailed inormation than ICD-9 codes, and using them
appropriately will reduce the need to recode claims
Key Takeaway #2:
Financial Neutrality is Top of Mind and Hard to AchieveFinancial Neutrality was a priority topic at the ICD-10 Summit, and attendees engaged in a
healthy dialogue with presenters regarding strategies or realizing the objective. Several
presenters mentioned the potential or negative cash fow throughout the ICD-10 transition
cautioning attendees to anticipate hiccups and to plan or nancial imbalance or a period o
no less than six months.
While most of the conversation centered on how to achieve neutrality, the Summit also
unearthed a collective perspective on perceived barriers, realistic expectations and challenges
around the initiative. Most stem rom communication breakdowns and disagreement on
exactly how to dene neutrality across multiple dimensions.
Blue Cross Blue Shield o Michigans (BCBSM) Roadmap to Achieve Neutrality
Moving rom ICD-9 to the ICD-10 code set isnt an exact science. A payer can test and emulaclaims based on what they expect to receive, but they cannot accurately mimic an actual cl
submission. Conversely, a provider will know what ICD-10 code to submit, but will not know
how a payer will respond to that code or reimbursement. Every trading partner will ace th
conundrum as it works through the code conversion. In his presentation, Dennis Winkler o
Blue Cross Blue Shield o Michigan emphasized that only when trading parties come toget
can they collectively develop a roadmap to achieve nancial neutrality.
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At the claim level
At the individual provider/acility
At a legal entity level At a logical grouping o providers/acilities
At the geographical location/area level
At the payer level
No idea
None o the above
At what level of granularity will you
measure neutrality?
23.6 %
7.9 %
5 %
7.1 %
10.7 %
15 %
19.3 %
11.4 %
1 Dimension 6-7 Dimensions
2-3 Dimensions 8-9 Dimensions
4-5 Dimensions > 9 Dimensions
For those companies targeting neutrality,
how many unique dimensions have you
targeted/identied?
32.9 %
55.7 %
5.1 %
20 %
32 %
12 %
22 %20 %
8 %
6 %
Audience Poll Getting Started Identiying Core ICD-10 Work Streams
Winkler highlighted there are several work streams that should be addressed during implementat
Assessing the technical and business impacts of ICD-10
Creating and applying payer-specic ICD maps
Executing complete and thorough testing
Training and communicating with all stakeholders, and
Establishing post-implementation monitoring and alarm triggers.
He also stressed that determining the operational status quo was instrumental in achieving neutra
Dening Specic Dimensions o Neutrality
From a payer perspective, neutrality means maintaining current claims acceptance rates, the
number and rate of inquiries, the rate of electronic claims, and claims reimbursement amou
(which is central to nancial neutrality).
However, the industry has struggled to dene specic dimensions o neutrality that can serv
as a oundation rom which to build models, predict outcomes and then work with trading
partners to test and analyze those predicted outcomes.
BCBSM has worked to maintain its operational status quo, however, by targeting six key
dimensions o neutrality:
Payment (Provider): Neutrality is based on identifying shifts of DRG payments and work
to minimize their eect
Benet (Member): Neutrality is based on no expansion or reduction in benets or
out-o-pocket costs as a result o the ICD-10 implementation
Revenue (Payer): Neutrality is based on no signicant increase or decrease in reimbursem
Clinical (Programs): Neutrality is based on having approximately the same number of
candidates in their wellness and care management programs that they have today
Operational (Servicing): Neutrality is based on a lack of increase in BCBSMs key performa
metrics, such as rst pass, pend rate, etc.
Financial (Overall): Financial neutrality refers to the cumulative eect of the variance in t
previous neutrality dimensions. Acceptable levels o variance across other dimensions co
result in an unacceptable overall variance. Extensive statistical modeling will be required
address this dimension
Because interruptions to payment models would have potentially negative repercussions o
provider relationships, BCBSM worked to dene the business stratications o payment neutra
and acceptable ranges or being considered payment neutral. His team also developed a
baseline or BCBSMs existing book o business using dened business stratications, identi
and anticipated payment dierences with conversion to ICD-10 and modied criteria in orde
to categorize anticipated payouts within acceptable ranges.
Using Data to Anticipate Payment Diferences
In doing so, his team developed three steps or identiying anticipated payment dierences
Creating ICD-10-based equivalent claims using a third party tool for claims creation and
using historical data
Manually re-coding ICD-10 claims to document probable DRG shifts
Asking external providers to re-code targeted ICD-10 claims from existing medical recor
The last step is critical because it leverages partners to help identiy high-risk, high-sensitivit
claims and demonstrates which claims are likely to be submitted. It helps both parties agree
the denition o neutrality. Payers can then better understand the inormation that provider
will likely send when using ICD-10 code sets, and providers can identiy gaps in medical reco
documentation standards. This is the key to testing and proong concepts that help payers
evaluate and validate payment neutrality with their partners.
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Budget
Training
Payer or provider partner readiness
Vendor readiness
Executive commitment
What do you believe is your
greatest exposure?
48.6 %
18.6 %
15.7 %
8.6 %
8.6 %
On-going solid communication plan
Communication plan but no ongoing dialogue
Occasional contact
What communications?
How do you view the strength ofcommunication channels between
external partners and your organization
regarding ICD-10?
29.5 %
33.3 %
33.3 %
3.9 %
Which external trading partners are likely
to present the greatest challenges to the
success of external testing?
Physicians Government authorities
Hospitals Sotware vendors
Clearing houses Payers
25.4 %16.8 %
5.3 %
20.6 %
12.9 %
19.1 %
Audience Poll Key Takeaway #3:
Collaboration among Trading Partners is Central to Success
The ICD-10 Summit unveiled shared sentiment among payers and providers around the
importance o partner collaboration throughout the ICD-10 migration. One session ocused
exclusively on this topic and eatured Cleveland Clinic and Medical Mutual o Ohio as co-presen
Together the two speakers equipped the audience with lessons learned, as well as best and
next practices or approaching ICD-10 as a shared initiative.
Attendees and presenters alike discussed the need or prioritizing clinical documentation,
preauthorization procedures and coding policies because they aect business operations
and the ability to achieve nancial neutrality.
While it is clear that specic ICD-10 transition activities will vary tremendously across organizat
and between payers and providers, the ICD-10 Summit unearthed a dialogue that placed
tremendous signicance on developing strong relationships. Collaboration or successul ICD
includes sharing detailed knowledge o internal workfows, increasing transparency to creat
trust, and undertaking a concerted eort to oster the good will necessary to tackle a projec
the magnitude o ICD-10 successully.
Lessons Learned rom Cleveland Clinic and Medical Mutual a Collaboration Case Stu
Cleveland Clinic has held true to its mission since its ounding in 1921 to provide compassion
healthcare of the highest quality in a setting of education and research. As the organizationprepares or its conversion to ICD-10, it is applying a disciplined technology-, training- and
collaboration-based approach that emphasizes provider and payer education, detailed knowled
sharing and a careul project management structure.
A Joint Discovery Mission
Cleveland Clinic identied its largest trading partner, Medical Mutual o Ohio, as one o its ke
ICD-10 partners. The two organizations agreed to embark on a discovery mission together
gain a collective understanding or how both companies processes worked and how ICD-1
would aect each o them. This shared knowledge was instrumental in helping the two
organizations set expectations, dene work requirements and commit to project sign o
obligationsthe elements necessary or successul migration.
One o the key eorts was to work together on the technology and process changes that wodisrupt clinical documentation and coding, patient nancial services and clinical research an
physician unctions. The companies objectives were to evaluate the way the organizations
currently used ICD-9 codes and to identiy specic gaps in clinical and business operational
readiness regarding the implementation o the new ICD-10 code set.
A Common Project Plan and Joint Testing Matrix
Cleveland Clinic mapped out two ICD-10 project budget proposals spanning the course
o three years; one refected an aggressive approach, while the other was more conservative
and actored in higher health inormation management and billers costs or the 2013 and
2014 nancial years. The dierence between the two was more than $7 million dollars.
Through revenue cycle training, strong clinical documentation, physician integration and
technology advancements, Cleveland Clinic sought to reduce its budget targets.More importantly, Cleveland Clinic knew that strong cooperation with Medical Mutual regar
ing nance, reimbursement and contracting strategies would be instrumental in lowering
costs. The two companies resolved to dene and set project priorities that would involve
key business and IT personnel as appropriate and then share them as a framework for
creating a joint roadmap.
The companies worked together to develop the project plan, including a crosswalk approac
or bi-directional ICD-9 and ICD-10 mapping. Their joint strategy also called or an ICD-10
crosswalk analytics tool to simulate and assess the potential revenue impact on both sides.
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Yes No Uncertain
Do you believe your organization has
budgeted appropriately for ICD-10 testing?
36.6 %
16.9 %
46.5 %
Yes No
Do you plan to do specic testing
based on claims scenarios specic
to the policy intent?
75.7 %
24.3 %
What are (or will be) the most signicant
challenges to your organizationssuccessful achievement of the ICD-10
conversion testing process?
Sta resources
Technical expertise
Coordination among business units/ unctions
Coordination with external trading partners
Platorm or sotware complexity
Vendor preparedness
Provider preparedness
Data or data standards
Testing inrastructure
17.8 %12.7 %5.1 %
5.1 %
4.4 %
12.4 %
16 %
15.3 %
11.3 %
Audience Poll Ongoing Communication and the Power o Goodwill
The other critical piece o the Cleveland Clinic / Medical Mutual o Ohio was something that
attendees heard repeatedly throughout the Summit: ongoing communication. Due to Clevel
Clinics size and volume o claims, the two organizations knew they would need to test near
every scenario. Both organizations have consistently worked to communicate their readines
accept new code sets and keep the process moving orward.
Through joint discovery, transparent communication, and sharing ICD-10 project test results
analyses, Cleveland Clinic and Medical Mutual o Ohio have determined their best practices gaining ICD-10 project momentum. They have also determined how to apply lessons learne
rom their successul collaboration on other mandates and healthcare initiatives, like HIPAA 50
The joint eort and approach they shared at the Summit is already accelerating their ICD-10 e
and has put Cleveland Clinic on pace to save more than $7 million in implementation costs.
Key Takeaway #4:
Risk-Based Testing is Critical
The announcement that CMS will delay the implementation deadline or ICD-10 adds more
uncertainty to the already-conusing nal phases o payer ICD-10 projects. For many payers,
the remaining project phases will ocus on testing ICD-10 migration solutions. According to
Summit presentation by Janice Young o IDC Health Insights, most payers will be heavilyinvolved in ICD-10 system testing by mid-2012; and other orms o testing such as regression
user acceptance,
perormance and comparison testing by late 2012. She based her assessment on results o a
IDC Health Insights survey o payers and released those results at the ICD-10 Summit.
While health plans are moving quickly into these testing phases, major questions remain
unanswered about how to approach testing, given the pervasiveness o ICD-10 impact acro
healthcare enterprises.
Blue Cross Blue Shield o Michigan and Humana are ocusing testing on
business neutrality goals
Dennis Winkler from Blue Cross Blue Shield of Michigan, emphasized that testing should focus
maintaining the operational status quo. This means keeping the business neutral with respeckey performance indicators such as claims acceptance rates, support inquiries, electronic cla
adjudication rates and aggregate claim reimbursement amounts.
He suggested that neutrality testing begin with a systematic approach to internally creating
ICD-10 test claims, including the use o certied coders to create claims rom existing medic
records. These claims should refect high-risk scenarios aecting payments, benets, revenu
clinical programs (wellness and care management) and operations. Blue Cross Blue Shield o
Michigan is creating internal test data targeted at testing this processes. However, the ultima
goal is to obtain test claims rom external trading partners who have created ICD-10 claims
rom existing medical records.
In his Summit presentation, Sid Hebert o Humana explained the process Humana is using to
develop their internal testing data. He emphasized that payers must develop test scenarios t
refect use o high-risk codes, specically claims that use codes expected to have high volumor high dollar values. Humana analyzed historical claims to identiy their high-risk scenarios.
Like any enterprise technology project, the time allocated to testing or ICD-10 is nite, while
the code-mapping permutations created by ICD-10 are not. As Humana has learned, the key
to minimize the risk to the business by ocusing eort on testing scenarios that could have t
most impact. By doing this Humana was able to reduce the number o ICD-10 testing scena
rom several hundred thousand to just a couple o hundred.
Payers and Providers agree on the necessity o a collaborative testing efort
Several presentations at the ICD-10 Summit ocused on how to start collaborative testing betw
payers and providers. Lyman Sornberger o the Cleveland Clinic and Annette Melda o Medi
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Core system replacement
Resource availability
End-to-end testing
External partner readiness
Budgetary constraints
Of these areas, what is your
organizations biggest challenge
or area of concern today?
25.8 %
9.1 % 9.1 %
16.7 %
39.4 %
Yes No
Have you developed measures to evaluate
the business impact of policies?
68.3 %
31.7 %
Audience Poll Mutual o Ohio discussed their anticipated testing process. Later this year Cleveland Clinic wbegin coding claims in both ICD-9 and in ICD-10. Medical Mutual will adjudicate and pay the
ICD-9 claims, while also processing the ICD-10 claims in their test system so the two entitie
can compare results and variances o high-risk claims. The analysis will ocus on complianc
and neutrality in key risk areas to both Medical Mutual and Cleveland clinic.
WellPoint is ocusing its testing on those claims at greatest risk o payment variation
WellPoint, the largest payer in the United States, is also taking a collaborative, risk-based
approach to external testing. Florentino Buendia, Provider Contract Director at WellPoint, nothat WellPoint uses several methods to identify the providers at most risk for payment variat
WellPoint uses the following method:
Identify provider contracts where reimbursement terms are tied directly to
ICD-9 diagnosis or procedure codes
Identify high-risk DRGs, procedures, and diagnosis codes (those most likely to change)
Create simulation models that re-price using ICD-10 language/terms
WellPoint has targeted eight hospital facilities for its rst phase of external testing. WellPoint gi
the providers high-risk ICD-9-based claims (those with high potential or signicant variatio
payment) and asks providers to recode them into ICD-10 claims based on the original med
records. WellPoint manually processes the claims and then jointly reviews the results with provid
Future phases will include a more complete end-to-end processing o claims and an expansto the general provider population.
Taking a risk-based approach to testing based on analysis o historical data is a common elem
to the testing approaches these ICD-10 leaders are taking. This includes identiying high-risk
codes, as well as identiying providers most likely to bill payers using these codes. Successu
external testing will require new levels of collaboration and information sharing among provid
and payers. While it may be uncomfortable to collaborate on such testing, the consequence
big surprises in payments ater the transition date will cause even greater discomort or pay
and providers alike.
Key Takeaway #5:
For Successful Implementation, the Devil is in the DetailsThroughout the two-day event, strategies or success took center stage during bothormal presentations and inormal networking discussions. On Thursday, attendees broke
into moderated, small-group exercises to tackle the issues they voted as most signicant
when they registered.
Readiness is a major concern; traditional change management strategies need
to go external
Whether they were concerned vendor, partner, or organizational readiness, virtually all
attendees expressed concern that their implementation would suer rom a lack o
preparedness. A common thread running through all the various recommendations and
best practices was to adopt a communicate early, communicate oten approach.
From a vendor readiness standpoint, the key recommendation was to conduct a baselinesurvey o all vendors and then use the results to prepare a ull assessment o each, includin
criteria to gauge their readiness. By stratiying the list and creating a dashboard to under-
stand the current state o each vendor, entities could then develop specic communicatio
plans to work with each one.
Both payers and providers cited partner readiness as one o their biggest concerns and
agreed that deliberate, enhanced communication among all internal and external stakehold
had to be a priority. Entities will need to manage multiple work streams (technology, busine
vendor, etc.) and ensure internal groups (such as contracts) are involved. The strongest
recommendation was to evaluate and determine the specic impact and risk o each partne
to ensure the right level o communication and coordination takes place.
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Business/Tech SMEs
Third party
Coder availability
Provider collaboration
Other
What people consideration has been
found to be most challenging?
13.6 %
6.8 %
22.7 %
54.6 %
2.3 %
Application architecture
Data architecture
Vendor implications
Reports and analytics
None o the above
What technology challenges
are you facing?
39.3 %
25 %
12.5 %
21.4 %
1.8 %
Yes No
Have you looked at how you will
prioritize your policy remediation work?
58.7 %
41.3 %
Audience Poll There are no shortcuts to remediating medical policies
Dr. Joe Nichols o Health Data Insights discussed the challenges and best practices around
remediating medical policies. His presentation ocused on the act that while most payers a
probably considering using crosswalks or maps to remediate medical policies, they might e
up with medical policies that are incomplete, or in some cases completely wrong. This will ta
payers urther away rom their goal o nancial neutrality.
The key, Dr. Nichols o Health Data Insights pointed out, was to step back and take a grounds
view o medical policies natively in ICD-10. Medical policies must incorporate the level ospecicity included in ICD-10 while prescribing actions in the delivery o healthcare services
based on medical rationale. Remediation must also incorporate the key objectives o medic
policies, i.e. policies must be clinically driven, demonstrate clear intent, accessible, understan
able, be the single point o truth and be traceable. In addition, medical policies must also
provide a mechanism or clear governance, be collaboratively developed and reviewed, be
accurately implemented and must be tested.
While redening medical policies for ICD-10, it is valuable to review the processes by which
policies are dened, coded and communicated. There are many players clinicians, coders a
systems engineers currently involved in policy denition. However, in most cases, there is
clear way to ensure that the intent o the medical policy was communicated clearly rom on
stakeholder to the next. There are also limited review processes to ensure that the end prod
(medical policy) refects the clinicians original intent.
Code-mapping eforts need to encompass more than the GEMs
By ar, the biggest undertaking or ICD-10 will be mapping the ICD-9 codes in use today to t
ICD-10 codes that replace them. Its a ar-reaching eort that will aect several areas o every
healthcare entitys business.
While the GEMs are a good start to code-mapping eorts, most Summit attendees acknowledg
that they wouldnt solve every need. Most healthcare organizations will use ICD-10 code ma
or a variety o purposes, such as identiying which codes will dene a specic policy, disea
management area, or benet categoryalways important or native updates to back-end
systems. Another use is identiying the specic codes used to analyze data beore and ater
implementation date to ensure accurate conversion o historical data to a consistent code se
Besides the possibility of not having all the codes an entity must consider, the GEMs simplyprovide a list o related codes without providing critical details that explain how and why th
codes are related, or where they dier. For healthcare entities, this means they will have to
spend a signicant amount o time and eort to evaluate those dierences.
During the small-group discussions, attendees recommended that mapping be tailored to
specic policies and edits, rather than relying on a single master map, and then sharing thos
maps with external partners. Moreover, because mapping wont be a one-and-done proce
there was a consensus that it will be important to consider the iterative nature o mapping t
manage rework and the inevitable ripple eects each may cause.
Managing ICD-10 transition across the enterprise requires attention to people,
processes and technology
Summit attendees all agreed that ICD-10 will have a ar-reaching impact o ICD-10 on peoplbusiness strategy, operational processes and technology inrastructure. In one presentation
Deloitte and Blue Cross and Blue Shield o Tennessee (BCBST) discussed the importance o
identiying and engaging an executive sponsor throughout the ICD-10. The discussion also
centered on the signicance o program structure and provided a snapshot o BCBSTs ICD-
team structure, which includes chie compliance, actuary, nance, IT, provider network, chie
medical and application representatives.
Other presentations and small-group discussions around internal readiness noted that existi
best practices around corporate governance could be ideal or ICD-10 projects, particularly t
ensure increased collaboration among business and technology groups. One o the stronge
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Benefcial or could be put to good use
Neutral no impact
Would be costly, but manageable
Potentially catastrophic
Irrecoverable
What would be the impact of a
two-year delay?
3.7 %5.6 %
22.2 %
55.6 %
13 %
Would a delay negatively impact other
healthcare reform efforts?
Yes No
24.1 %
75.9 %
Do you believe a delay will result in
improved readiness?
Yes No
36.4 %
63.6 %
Audience Poll recommendations was to structure the ICD-10 Program Management Oce (PMO) along thsame lines as traditional IT PMO organizations, because o the proven capabilities o such a
structure. However, i an organizations existing IT PMO takes on ICD-10, its KPIs and associat
metrics should be redened to ocus on the objective o ICD-10, rather than the business or
technology group it usually supports.
Both Deloitte and BCBST stressed the importance o bringing all internal stakeholders into
the conversation early on and emphasized that compliance oten has dierent meanings t
people and across departments. One team in the small-group exercise discussed compliancchallenges and recommended that the denition o ICD-10 compliance be dierent rom
HIPAA 5010. Instead o compliant transactions being interpreted between entities, the team
said the rule o law must have a hard cutover date or compliance, meaning parallel submissio
or the same date o service is not an option. The team also noted that paper claims should
treated the same as electronic ones.
And rom a people perspective, Summit participants agreed that the biggest inhibitors to inte
readiness are resource constraints, lack o in-depth training, and deep knowledge o code se
across the organization. This team recommended role-based training delivered right when spe
constituencies need it, a comprehensive knowledge base with easy-to-use look-up tools, impro
processes for collaboration, and potentially outsourcing work that requires specic skill sets.
Key Takeaway #6:Overwhelming Opposition to an ICD-10 Delay
Less than two days beore the ICD-10 Summit convened, the U.S. Department o Health & Hum
Services announced it was considering delaying the ICD-10 implementation deadline or cer
healthcare entities. The potential delay proved to be a hot topic throughout the two-day ev
with many expressing a desire to understand the prevailing mood among their ellow attend
On Friday morning, attendees participated in an anonymous 13-question survey about the
delay and its potential impact on the industry. Based on the results, a signicant majority o
attendees eel that despite good intentions to the contrary, a potential delay o the ICD-10
compliance deadline could have ar-reachingand highly negativeimpact to the healthc
industrys eort to implement the mandate.
The study ound overwhelming opposition to an ICD-10 delay among respondents,all o whom are senior healthcare proessionals actively involved in their organizations ICD-1
transition and carrying signicant responsibility or the overall success o the project.
The majority o survey respondents stated any delay would be problematic and would not
have the eect intended by the Centers or Medicare and Medicaid Services (CMS). Below ar
some o the key ndings:
Overwhelmingly, respondents believe that while a one-year delay would be costly,
but manageable, a two-year delay would be either potentially catastrophic or cause
an unrecoverable ailure
If CMS does delay the compliance date, respondents almost unanimously support clear
communicated and enorced interim milestones to ensure the industry doesnt encoun
the same problem a year rom now
The annual cost of delaying the ICD-10 deadline could exceed $4 billion, based on a 30
percent increase in costs or every year o delay
The survey data indicate a strong preerence among healthcare proessionals or not delayin
ICD-10. Additionally, i a delay is inevitable, most recommend that it not be more than one
year. This desire is likely driven by the concern that a delay will result in budget reezes, work
slowdowns and redeployed resourcesall of which would be extremely dicult to recover
once progress starts up again.
Given the nature of enterprise business and resource planningas well as the multitude of
highly important initiatives that compete or the best talent and most budgetjust the
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potential or delay is giving healthcare entities a reason to step back rom their ICD-10 proje
While there may be a few entities that can truly use the additional time to improve their readin
the majority o respondents believe this will not be the case. Instead, costs are likely to spira
higher, and valuable resources may be lost as the industry waits or the outcome o CMS proc
to determine whether the deadline will slide.
The near-term issue is uncertainty. Until the industry knows the ultimate deadline or ICD-10
progress will be stalled. In addition, i the eventual delay is more than a year, the costboth
actual dollars and the eort it will to take regain momentummay be almost unbearably hThe imperative for CMS now is to complete its evaluation as quickly as possible and alleviate
uncertainty around the deadline. I the date does slide, CMS needs to choose a path that wil
keep the industry moving orward toward successul ICD-10 compliance.
A ull report o the survey results is available at
http://www.ediecs.com/downloads/EdiecsSurvey-ICD10Delay.pd.
Conclusion
The ICD-10 Summit generated intense discussions around best practices and lessons learned
organizations already in the throes o their projects. It provided a orum or participants to f
ideas and create rameworks to address particular issues. The key themes refected in this rep
will continue to serve as guidelines or other organizations anduntil a more comprehensiv
study is undertakenwill provide a summary o the industrys current thinking on how bes
approach ICD-10.
With a project the magnitude and complexity of ICD-10, the nal objectives and best practi
or achieving them will be a moving target. Summit attendees recognized this and ormed a
online community to continue the sharing o inormation and ideas.
Even with the uncertainty around the nal deadline date, all attendees expressed a strong
intent to continue with existing plans and schedules. This may be one o the most importan
takeaways o all. In the ace o an unclear deadline, immense internal readiness challenges a
unprecedented levels of external collaboration requirements, healthcare organizations shou
view any potential delay as an added buer against unexpected challenges, rather than an
extension o the deadline.
No one knows exactly what a successul ICD-10 implementation looks like yet. It will likely becombination o proven best practices around governance, project management and organizatio
readiness with new approaches or mapping enormous amounts o data and testing the var
scenarios to ensure a little business impact as possible.
Ediecs is making this report publicly available as a service to the healthcare industry. Excerpts rom
this report (including charts) may be used or editorial purposes without prior permission rom Edi
provided:
Edifecs is acknowledged as the source of the content
Charts are displayed with only minor and necessary edits or changes
A link to the full report is included
(http://www.ediecs.com/downloads/ICD10SummitTakeaways.pd)
The survey results reported in Key Takeaway #6 represent an aggregate o voluntary and anonymoresponses rom more than 50 senior healthcare proessionals. The aggregated data and Ediecsinterpretation o it should not be construed as representing any specifc opinion belonging to otherhealthcare organizations mentioned in this report.