OASIS Alert

Published on Tue Dec 03, 2013 PDF

Is your documentation up to ICD-10 standards?

You may feel like you’re running just to keep up with the seemingly non-stop changes your agency is faced with of late. But if you’ve been leaving your ICD-10 transition plans on the back burner, it’s time to turn up the heat.

No delay: Don’t expect the recent government shutdown to slow down the Oct. 1, 2014 deadline, said Arlene Maxim, RN founder of A.D. Maxim Consulting, A.D. Maxim Seminars, and The National Coding Center, in Troy, Mich. Unfortunately, the shutdown is more likely to have a negative impact on the smoothness of the transition, she said during the Eli-sponsored audioconference “Choosing & Training a Home Health ICD-10 Transition team.”

Choose Your Transition Team

Many agencies report that they’ve been so busy with the myriad of other pressing matters facing home health providers, including new survey protocols and an increase in medical reviews, that they have put the ICD-10 transition on the back burner, Maxim said. But if you don’t get a transition team in place and get started on the necessary work, your agency will suffer, she warned.

The transition team will be responsible for developing a training plan, working with ICD-10 trainers, and determining the education needs among referral sources as well as internal staff, Maxim said. The team will also need to assess the readiness of staff and billing/IT systems to make the transition. This will include quantifying lost productivity during the transition and assessing the need for outside coding assistance. The team will also need to develop processes for the changes to your current intake procedures.

Your agency’s multi-disciplinary transition team should be composed of leaders from each department in your agency, Maxim said. Be sure your team includes:

• Administrator
• Senior Management
• Director of Clinical Services
• Chief Financial Officer
• Senior IT Staff
• QA/QI Department Representatives
• Billing Coordinator
• Coders
• Marketers
• Compliance Officer

Once your team is in place, it’s time to get to work. Make certain you follow these nine steps for a successful ICD-10 transition.

Step 1: Identify Resources

This includes conducting an information systems inventory and assessing vendor readiness and support, Maxim said. Be sure to get the name and contact information of someone who you can stay in touch with who will let you know what the vendors are doing to prepare. Get this information now so you’re not scrambling during the actual transition.

The transition team will also need to identify necessary tools for the conversion, Maxim said. Will your current hardware accept the changes necessary? The team should identify areas needing operational and policy changes at this time as well.

Step 2: Inform Staff

Start this step by conducting staff awareness sessions, Maxim said. People need to know that the transition is less than 12 months away. Explain what ICD-10 is and why healthcare providers are required to change. Let staff know what they can do to be better prepared. You will also want to assess staff to determine their level of readiness.

Step 3: Assess Impact on Your Agency

Identify stakeholders in the ICD-10 process and determine their unique needs. Be sure to include referral sources as well as internal staff, Maxim said. Perform a gap analysis of staff and systems to determine their actual performance in comparison to the necessary performance and begin training to close the gap.

Begin to assess clinician and code set user knowledge. Clinicians will need to beef up their documentation, Maxim said. OASIS responses can’t be check boxes any longer, she said.

“Documentation will make or break this process,” Maxim tells Eli. ICD-10 will require a higher degree of specificity. Assess clinicians’ documentation practices and begin improvement efforts. You’ll also need to determine whether your coders require anatomy and physiology training to better utilize the detail of the ICD-10 code set. Some coders may need more training than others.

Step 4: Identify Challenges and Create the Project Plan

Create a communication plan that outlines who you need to communicate with and what you need to share, Maxim said. Develop a coding education plan. Research educational resources and connect appropriate staff with these resources.

Be proactive to head off documentation gaps with physicians.

Step 5: Secure a Budget

Your agency will need to plan a comprehensive and realistic budget for making the ICD-10 transition, Maxim said. Remember to reassess and revisit the budget throughout the implementation period.

Be sure your budget includes:

• Resource and system needs
• Stakeholder education and training needs
• Software upgrades and system changes
• Productivity loss including any needs for temporary staff

Step 6: Contact Your Partners

Identify and ensure involvement and commitment of all internal and external stakeholders. This includes vendors, physicians, and clearinghouses, Maxim said.

Step 7: Train the Test Team

You’ll need to conduct ongoing staff training throughout the transition period, Maxim said. You’ll also need to test and validate system changes before going live. Remember to work with your MAC to make sure their systems are set up and ready to go.

Establish a plan to monitor work flow volumes during the training period to minimize backlogs prior to go-live, Maxim said. Also establish a plan to reinforce physician documentation training. If you train your marketers about this aspect of the transition, they could be a valuable resource in helping to get your referring physicians prepared.

Step 8: Prepare for Go-Live

Coordinate educational needs with meaningful use, quality measures, patient outcomes, and clinical decision support requirements. Finalize and test any necessary system changes.

Assess case mix impact using GEMs to compare. Provide intensive coder education.

Monitor coding accuracy and reimbursement impact.

Step 9: Measure and Manage

Set milestones for each action item and monitor for compliance in this last step, Maxim said. Measure coding accuracy, productivity, and effect on reimbursement. Monitor documentation improvements, too.

Provide continued coding and documentation education. You’ll need to do this over and over because staff won’t get it all down pat right away, Maxim said. Evaluate knowledge, skills, and return on investment to determine where you’ve been successful and where you need continued work.