DMN: What advice would you give to those working to prepare?
ST: Our Association has been aggressively educating our members on how best to move forward with ICD-10. We are encouraging practices to adopt a step-by-step implementation approach, starting with the creation of an implementation "team" with both administrative and clinical staff involvement. An internal review of how the code set will impact the practice should be the next step and included there would be the identification of all computer systems impacted by ICD-10 and staff training requirements. Outreach to these vendors should then be conducted and an upgrade/replacement/training timeline established. Creation of a budget to present to senior management is also a critical step. Review of current clinical documentation must also be completed — either as an internal process of assigning ICD-10 codes to previously adjudicated claims or dual coding of current claims. Outreach to external trading partners is a critical next step as is the identification of testing protocols and dates for when claims can be submitted for testing. Establishment of a comprehensive contingency plan is also a very likely and necessary step for many practices.

DMN: Anything else you'd like to add?

ST: Our research results highlight an industry that is lagging behind in terms of readiness. We believe that end-to-end testing is a critical step to minimize the chance for disruption of claims. However, CMS just announced that they do not plan to externally test with providers. We believe that is a mistake on the part of the government and have urged them to reconsider this policy. In addition, we are concerned that some software vendors have yet to communicate their upgrade/replacement plans to practices and have called on these vendors to immediately share with their practice clients their plans to upgrade or replace software, on clearinghouses to communicate their testing plans and ICD-10 options, and on health plans to publicly release their payment policies and testing schedules.

We will continue to monitor the readiness levels of our member practices and their critical trading partners, and communicate our findings, concerns and recommendations directly to the government.

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