Preparing an ICD-10 Contingency Plan

October 1, 2015

By: Steph Weber As a solo practitioner, I'm putting my faith in ICD-9 to ICD-10 crosswalks to code properly and avoid damaging my practice's bottom line.

Most physicians have dedicated significant financial resources and years of planning to ensure that their ICD-10 implementation goes smoothly for their practice. For most practices, it’s best to prepare a viable ICD-10 contingency plan for all the troubles that will come up after Oct. 1, 2015.

Here’s how to formulate that plan and why it is such an important step of ICD-10 preparation.

Check in with staff

Physicians are certainly worried about navigating the transition, but other healthcare employees are feeling tremendous pressure as well. From nurses to billers to auxiliary staff, it’s important to keep them in the loop. “Talk to staff to determine their concerns,” said David Zetter, founder and lead consultant of Zetter Healthcare, a practice management consultancy located in Mechanicsburg, Pa. “[Ask] whether they feel they have the tools to do the job properly.”

If your staff is feeling ill-prepared, bring in reinforcements. “Practices can turn to state medical societies, state specialty associations, and CMS’ Road to 10 website,” said Ricardo Martinez, an emergency physician and the chief medical officer of North Highland, a multi-industry global consulting firm located in Atlanta, Ga. His firm partnered with CMS on the website, with physician input largely driving the layout and design. The site also has useful case studies and short video interviews with physicians. 

Focus on key codes

Depending on the medical practice, it’s likely that a majority of the billing revolves around a set of frequently used codes. Developing crosswalks for these codes is imperative. “Physicians should have already determined the ICD-9 codes that they used in 2014 and converted them to ICD-10,” said Zetter. The crosswalk list should be documented in writing and distributed to physicians and pertinent staff.

This move will save practices a lot of time, since ICD-9 codes from previous visits can be converted to ICD-10 codes in the billing system. According to Zetter, not only will the codes be preloaded for upcoming visits, but physicians will be able to easily select the proper ICD-10 code without having to search through long code descriptors.

Martinez said he believes it’s best to focus on the most frequently used codes. “Practices should focus on the codes with the biggest potential impact to drive revenue,” he said. “Six [percent] to eight percent of [a practice’s] codes drive 80 percent of the revenue, so this is the place to start if you feel behind.”

Dial in documentation

Besides billing the correct codes, documentation is important in attaining appropriate reimbursements in ICD-10. Despite the initial anxiety produced by the new documentation standards, Martinez has found that many small practices discover “that the documentation is not as hard as they thought, once they understood the requirements.” Practices are encouraged to review the specialty-specific documentation guidelines published by CMS.

Documentation reviews are a form of audit protection too. “Providers should have documentation reviews completed to ensure they are documenting the full code descriptors,” said Zetter. This can help to avoid the fallout of pre- and post-payment audits, during which payers may deny or recoup payments due to insufficient chart documentation.

Bolster financial reserves

No matter how well-prepared a practice is for ICD-10, there will inevitably be some bumps in the road. This is especially the case when dealing with multiple outside agencies. Unfortunately, those bumps can have a dramatic and negative effect on revenues.

“If a provider is highly dependent on state Medicaid or workers’ compensation payers, then setting aside two-to-six weeks of financial reserves might not be a bad idea,” said Matt Dutton, a consultant with Freed Associates, a healthcare advisory firm based in Kensington, Calif. “If a provider's revenue stream is dependent on large commercial payers or Medicare fee-for-service, chances are that revenue will not be disrupted if the provider submits accurately coded ICD-10 claims.”

Besides cash reserves, Zetter recommended that physicians ask their banking partners to extend lines of credit. This will provide an additional buffer in the event that pre- or post-payment audits restrict cash flow.

Last minute planning

It’s important that physicians remember there is still time to plan a successful ICD-10 transition. “This is going to be a one [year] to ten year process since some practices, like cardiology and gastroenterology, only see certain patients every two [years] to ten years based on their preventative care needs,” said Zetter. “Previous charts and encounters will still need to be converted.”

Martinez looked long-term as well. “By investing in training and testing, practices can feel confident in their ability to manage the process,” he said. Plus, the year of coding flexibility offers additional time to learn from any mistakes made early on. The learning curve will continue well beyond the passage of the Oct. 1 deadline.

Of course, planning a successful transition to ICD-10 is the ultimate goal. However, implementing these backup strategies may offer a bit more peace of mind as you navigate the process.

Steph Weber is a freelance writer hailing from the Midwest. She writes about healthcare, finance, and small business, but finds her passion for the medical field growing in sync with the ever-changing healthcare laws.