Posted By Monique Dever On February 17, 2015

A 12-step plan for ICD-10-CM implementation for local health departments

Public health department’s billing staff may have some huge challenges come October 1, 2015. Don’t take risks – start getting ready now!


The upcoming 10th edition of the International Classification of Diseases (ICD-10), is meant to be a great improvement over the 9th edition, but it could mean severe financial risks if public health departments are not ready. All public health departments must ensure they have upgraded their system and trained their staff on ICD-10 codes prior to October 1, 2015 to avoid disruptions of claims reimbursement. It is a big change so plan and prepare for it.


If you have not yet begun the transition preparations, you will need to focus on a fast track implementation process. This transition process can take 12-23 months of prep and training, depending on the size of the department. Keeping a binder with all the charts and forms and details is a great idea to make sure everything is in order and on time. Segment the binder into key areas and tasks. The American Medical Association (AMA) has outlined a 12-step approach to help you be successful in the preparedness for implementation.


Step 1 – Organize the implementation effort.

This can take 2-4 weeks. It is meant to for you to become familiar with ICD-10 requirements (see my earlier blog on the benefits of ICD-10-CM), identify your team leader as well as key personnel involved. During this period you will need to establish a weekly meetings schedule and set your budget. This is the perfect time to begin assembling your binder.


Step 2 – Analyze the impact of ICD-10 implementation.

This period may last for 2-3 months. It will begin with an analysis of the current ICD-9 usage: processes, electronic systems, and staff that all use ICD-9. Then you will need to identify work flows that may need to change to implement the new code sets, such as data collection forms, encounter forms, etc. You will need to analyze if you have the right staff in place or if you should hire a consultant.


Step 3 – Coordinate with your vendors

Depending on the vendor and technology platform, interactions and scheduling can last for 1-2 months. If your system is old client server (before the internet) then installing an upgrade to ICD 10 will require more time, effort and planning. On the other hand, if you have a cloud-based then upgrade is much simpler and smoother. It is almost a non-event for you as the EHR vendor can do the upgrade automatically without your involvement. Do contact the EHR vendor and make sure they will have their systems ready and establish a time when they can install the upgrades for you. Make sure to note any down time and prepare for the worst especially if it is an older client server system with servers. Review if there are changes to your contracts with the vendors and if there will be any expenses for upgrades, including any purchase of new hardware to accommodate the new processes and work flows.


Step 4 – Create a realistic budget

Depending on your EHR vendor, there may or may not be additional costs related to ICD-10 change over. After you have a detailed conversation with your vendors, take approximately 2-4 weeks to put together realistic numbers for all expenses related to the transition. Revisions to the budget may happen midstream; expect them. Just watch for hidden costs. More than likely, if your EHR is cloud based, the vendor is not likely to have any additional ICD-10 charges, be happy and celebrate that your vendor is not going to nickel and dime you for everything. If you are considering purchasing a new EHR, make sure that ICD-10 and future meaningful use stage 2 and 3 upgrades are included, at no extra cost, as part of your contract.


Step 5 – Contact your trading partners

As you may know, billing claims to payers go through clearinghouses. Clearinghouses, billing services and payers are all planning the implementations as well. Communication with each partner is critical for any billing success. Plan for testing any processes and other activities these partners may require of you. This step can most likely fit inside a 1-2 month window. This step may be taken care of by your EHR vendor saving you time and effort.


Step 6 – Implement system and/or software upgrades.

Depending on your EHR vendor, this may take the longest of all the steps running 3-6 months. Find out from trading partners when they will be ready to run test transactions with the new codes. Find out if you need to renegotiate your contract, and most importantly find out if ICD-10 could affect payment schedules, medical reviews, audits, or coverage. For a cloud based EHR, this may require no effort from you as the vendor can upgrade all this without involvement from you and your IT team.


Step 7 – Conduct internal testing

Prior to going live, some testing will need to be done. The effort involved here will also vary depending on your EHR technology and your vendor. Test your system and make sure it can accept the new codes and processes, allow time for vendors to come in to conduct testing, and review and correct any issues. This process should only take approximately 1-2 months. Again, for cloud based EHR this may be simpler.


Step 8 – Update internal processes

By now, you should have identified all the internal processes that are currently using ICD-9 codes or workflows and forms that need to be changed. Over the next 1-2 months you will need to update all these things such as administrative transactions, reporting processes clinical reports and writing orders. Be sure to review and compare existing documents to the clinical details needed to code for ICD-10 as well as documentation for required reporting.


Step 9 – Conduct staff training

The 10th edition of the codes will include a lot more specifics regarding detailed physical location. Identify all staff members that will require training, which includes everyone who currently uses ICD codes. Identify what level of training (there will likely be many people that will need training not only on the new codes but also in anatomy) and create a training plan. Don’t forget to update your new employee training manual and orientation program. Scheduling monthly or quarterly review sessions after completing this 1-2 month training period is a great idea.


Step 10 – Conduct external testing

This testing phase will last 1-2 months or as long as necessary to make sure all is working as it should. This will be conducted between you and each of the partners. Review results and fix all issues as they arise.


Step 11 – ICD-10-CM Implementation date October 1, 2015

This is the big day. The Centers for Medicare and Medicaid Services (CMS) has stated that claims processing interruptions is a high risk possibility. Funding is already low for public health departments. So be prepared to cover expenses for any interruptions of payments due to rejected or delayed claims reimbursements. Establish back-up financial resources prior to implementation. The change to ICD-10 will take place on October 1, 2015 with no crossover period allowed.


Step 12 – Monitor use of ICD-10

For the next 3-6 months and ongoing, monitor closely the use of ICD-10 codes to ensure proper submission and receipt. Double check reimbursements to verify amounts. Monitor all communications with partners. It is always a good practice to conduct audits to ensure proper codes are being used.


The AMA’s 12-step action plan has forms for each of the above steps and documentation processes.   Ready or not, here it comes! So if you need help getting through this, download a copy now.

About Monique Dever

Monique integrates research and networking with her passion for health and well-being to provide important, up-to-date news, resources and current events to the public health communities. She is the Marketing Executive for Patagonia Health, an Electronic Health Records (EHR) software company focused on the public health sector.