Health Information Management

The ICD-10 implementation delay and its effect on coders

JustCoding News: Inpatient, May 9, 2012

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The wait is over—HHS has announced a proposed rule that would postpone ICD-10-CM/PCS implementation from October 1, 2013, to October 1, 2014, if finalized.

Be prepared for just about anything, experts advised when CMS said in February that it would initiate a process to postpone the implementation date. The agency provided no specific information about a timeline for the delay until it announced the proposed rule April 9.

HHS initially announced the delay despite issuing a final rule to adopt the new code set by October 1, 2013, more than three years earlier. Some wondered after the February announcement why CMS would delay ICD-10 at this stage of the implementation. In an April 9 press release announcing the proposed rule and new implementation date, CMS asked, “What does the delay mean for coders who have spent the past several years psychologically preparing for a countdown to October 1, 2013?”

For coders, in particular, a delay in ICD-10’s implementation has definitely caused angst, says Gloryanne Bryant, RHIA, CCS, CDIP, CCDS, regional managing director of HIM, NCAL revenue cycle, at Kaiser Foundation Health Plan, Inc. & Hospitals in Oakland, Calif. “I think this is a disappointment among coding professionals, and this can ¬extend the anxiety of the change in general terms,” she says.

What are advantages, disadvantages of a delay?
Rather than seeing the delay as a setback, coders should view it as valuable time to continue to improve processes and enhance readiness, says Andrea Clark, RHIA, CCS, CPCH, chairman, CEO, and founder of Health Revenue Assurance Associates in Plantation, Fla. A delay will give coders more time to drill down into data, identify areas for documentation improvement, and implement CDI efforts, she says.

Bryant agrees. “More time in and of itself is an advantage,” she says. “This may spread cost out a little farther, which might help some. For those who are currently behind in planning and implementation, a delay will be an advantage.”

The delay could also serve as a foundation for more meaningful dialogue among coders and physicians, says James S. Kennedy, MD, CCS, managing director of FTI Consulting in Atlanta. “I hope that coders welcome this as an opportunity to engage their physicians, hear what their fears are, and negotiate win-win solutions,” he says.

Ideally, physicians should direct the development of ICD-10 with coders, hospitals, payers, and the Centers for Disease Control and Prevention, says Kennedy. “I believe that adding a physician group, such as the College of American Pathologists, the AMA, or the American College of Physicians, as a fifth Cooperating Party would be a strong move that unites all parties invested in the clinical language we are to use in our day-to-day patient care activities,” he says.

However, some disadvantages also accompany delayed implementation of ICD-10.

“There has been a lot of work already done in the healthcare industry in preparation for ICD-10,” says Bryant. “This work equates to monies spent already. The education and training timeline may need to be moved. Those that have already had some ICD-10 training may need refresher training now to retain the knowledge going forward.”

Another concern is the current ICD-9-CM code freeze, which would continue to be prolonged until ICD-10, says Kennedy. “This freezing of ICD-9 does not allow for improvements in the disease specificity that we need to measure outcomes,” he says.

Some wonder whether a delay could simply cause more procrastination. Sue Bowman, MJ, RHIA, CCS, director of coding policy and compliance at the American Health Management Information Association (AHIMA) in Chicago, fears that providers and others advocating the delay will continue to procrastinate and postpone ICD-10 preparation activities until as close to the deadline as possible, defeating the purpose of a delay.

“People argue that it gives providers more time to prepare, which may be true, but the problem with the 2009–2013 timeframe is that nobody started in 2009,” she says. “It’s not really clear whether the delay is going to really help people achieve compliance or just delay people’s worrying about compliance.”

Is waiting for ICD-11 a viable option?
The World Health Organization has stated that it will release ICD-11 by 2015.

However, the United States then must clinically modify the code set and develop a procedural code set, says Bowman. She anticipates that process will take seven or eight years. This means providers could realistically start using ICD-11 in 2022 or 2023 at best, she says, adding that the United States can’t wait that long to replace the outdated and failing ICD-9-CM system.

“Waiting that long just does not make sense due to the many benefits the ICD-10 coding system can bring to healthcare,” says Bryant. “We really need ICD-10 and the benefits of improved clinical data. For those providers that have an integrated delivery system, this might be more challenging and have some logistics issues.”

What should providers do now?
Experts agree that halting ICD-10 preparations is not the answer. “All hospitals should continue with their education plans,” says Clark. “Once we get a firmer foundation of what the date will be, you can always readjust the timeline. Hospitals can’t sit in fear and become immobile.”

Bryant says hospitals should determine the following:

  • Which key milestones and steps may ¬require revision because of the delay
  • The effect on previously secured funding
  • Whether a delay will extend implementation costs beyond current budget estimates, and by how much

Other plans for 2012 should include documentation assessment and preliminary coder training, says Bryant, with a focus on the following foundational core competency areas:

  • Medical terminology
  • Anatomy and physiology
  • Disease process and pharmacology
  • ICD-10 coding guidelines

In-depth ICD-10 coder training should begin approxi¬mately six months before the go-live date. Kennedy is aware of several hospitals that had planned to start using the new coding system January 1, 2013, prior to announcement of the possible delay. These hospitals plan to begin in-depth coder training as early as this summer, he says.

A delayed compliance deadline could be problematic with respect to scheduling training and perhaps incurring additional training costs, says Bowman. “Now, it raises the question of when will it be? This is an area where I think we will see additional cost. The people who have been trained to become trainers will have to maintain their skills and stay up to date,” she says. “Coders will need to be in some type of holding pattern with their knowledge. If you’re not using it every day, it’s hard to keep it up.”The delay will affect any organization or training program that modified curricula to accommodate the 2013 date, says Bowman. “It’s not an easy process to change an entire academic curriculum, particularly because you’ve got some students in the system already,” she says.

Hospitals should be reviewing queries to ensure that they are up to date and incorporate ¬infor-mation necessary for ICD-10, says Kennedy. They should determine whether their electronic health records (EHR) are compatible with the specificity of ICD-10. If not, vendors should provide a clear timeline for activating this capability regardless of the compliance deadline, he says.

The timeline shouldn’t affect when or whether hospitals educate physicians about documentation necessary to support ICD-10, says Clark. “[Y]ou don’t teach doctors how to code,” she says. “You teach them how to build better documentation in order to assign an ICD-10 or ICD-9 code. You can continue that process of documentation improvement without uttering the words ICD-10.”

“I think that one thing this has taught everybody and shown is that this is a big transition that was perhaps underestimated by some in the beginning,” says Bowman. “So keep it at, and that will ensure that you’re ready.”

Tara Blum, RHIA, CCS, manager of clinical coding at Northwestern Memorial Hospital in Chicago, says her facility will move forward with implementation plans despite the delay. Her organization’s prioritized to-do list includes:

  •  Finalizing ICD-10 coding salary structure
  • Continuing to actively recruit new graduates and ¬reducing reliance on contract coders
  • Implementing computer-assisted coding to help offset productivity losses
  • Assessing coder skills before training
  • Developing and implementing tailored ICD-10 educational plans for each coder
  • Dual coding in ICD-9 and ICD-10 until going live with ICD-10

Comments on the proposed rule are due within 30 days of publication in the Federal Register April 17. Comment on the proposed rule at

Editor’s note: This article was originally published in the May issue of Briefings on Coding Compliance Strategies. Email your questions to Senior Managing Editor Andrea Kraynak, CPC, at

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