Creating an ICD-10 Action Plan: Systems, Budget, and Documentation

November 15, 2013
Keith L. Martin

An internal systems assessment, developing a budget, and looking at documentation are key elements to prepare for the ICD-10 transition.

While the transition to the ICD-10 code set will mean reassessing your medical practice's processes, health IT capabilities, and other parts of daily operations, don't forget that like any major change, you'll need to have a budget in place.

"[ICD-10] will impact your bottom line," said Robert Tennant, senior policy adviser in the government affairs department for the Medical Group Management Association (MGMA). "The question is: … how to avoid as much productivity loss as possible?"

Tennant recently unveiled an action plan for medical practices to deal with the ICD-10 transition at the MGMA's Annual Conference in San Diego.

Taking into account factors such as education, changes to superbills, IT costs, increased documentation, and cash flow disruption, the MGMA recently estimated the costs of the ICD-10 transition at $2.7 million for a typical large medical practice with 100 employees; $285,195 for medium practices with 10 employees; and $83,290 for small practices with three employees. Furthermore, MGMA estimated the cost to upgrade or replace a practice management and EHR system for a practice with 10 full-time employees at $201,690.

Those are staggering numbers for an unfunded mandate from the government, especially for small medical practices, Tennant noted.

So it is very important that practices start creating a budget for how they will pay for needed IT infrastructure upgrades, possible contract revisions with a legal consultant, staff time and physician productivity losses, consulting services, and much more.

And practices should also provide for some contingency planning, Tennant said, for example, if their vendors are not ready by the Oct. 1, 2014, transition date, if an excessive number of claims get rejected, or other unplanned events occur.

"You have to maintain your practice," he said. "Perhaps now is the time to establish credit with a local bank or even postpone some capital investments. …You need to ask 'What if we go three months and don't get paid?'"

In addition to creating a budget, Tennant also advised medical practices to conduct an internal systems assessment as part of their action plan. This explores areas including all work flow processes that utilize codes, documentation issues, and a good look at your computer systems to see if you'll need upgrades.

"And remember, when you move from one practice management system to another or another EHR … that may require hardware changes as well," he said.

And, of course, part of your action plan should deal with understanding the impact on clinical documentation, Tennant advised.

"We have a tendency to say we code to get paid," he said. "That will change, especially with health plans taking a hard line on ICD-10. You can't be guessing at things; you need to code what is before you. You can only code what you see in front of you."

Tennant said that the professional coding group AAPC has estimated a 15 percent increase in documentation time due to ICD-10, so practices should factor that into their post-ICD-10 operations.

To prepare, Tennant advised practices to begin evaluating the extent of the code changes specific to their specialty, a great way to pare down the 69,000 codes to those that matter most. He also recommended practices review documentation to assure it is adequate to support the new codes, and to decide the best approach to code assignment, whether it is a physical book or computer program or a smartphone or tablet app.

Tennant suggested that practices test providers and staff now by asking them to take existing ICD-9 codes and find their ICD-10 equivalents, to get them used to the new system.

"If they can't get [to that ICD-10 code] … those are the physicians and providers that need the education," he said.

This is the second of three articles on Tennant's proposed "action plan" for medical practices to prepare for ICD-10. Stay tuned to the ICD-10 Topic Resource Center for future installments.