A successful ICD-10 implementation plan must encompass the entire organization. It should identify specific actions and assign responsibilities and deadlines for achieving them, including changes to processes, policies and procedures, as well as educational needs. It should also identify any need for increased staffing or consulting services to assist with coding backlogs, monitoring of coding accuracy, etc., as well as system upgrades or changes necessary to accommodate the new code set. The health plan should establish a budget for accomplishing the transition and estimate the financial impact the expected loss of productivity and disruptions in cash flow will have.

1. Establish an enterprise-wide implementation committee.

The ICD-10 implementation committee must be composed of representatives from all key stakeholders, including, but not be limited to, representatives from health information management (HIM), senior management, and medical staff, financial management and information systems. A project manager must be appointed to serve as leader of this committee, coordinate meetings and be responsible for the entire project. The committee members should have a working knowledge of ICD-10 and how it differs from ICD-9, as well as the expected short- and long-term financial and personnel impact of the implementation. The committee must develop an implementation plan with timeframes.

2. Conduct an ICD-10 impact assessment.

The impact assessment must identify the impact on key business processes, including health plan contracts and coverage determinations. It should also identify any contract modifications that may be necessary to accommodate the greater specificity required for ICD-10 and any resulting adjustments to payment terms. Additional documentation requirements and new diagnostic codes may also cause revisions in coverage determinations.

Current data flows; work flows, operational processes, policies, procedures and reports that will be affected must be documented and evaluated. Consideration must be given to the necessity of accommodating two versions of the ICD code sets for an extended period of time. How long both code sets will be supported, what additional storage capacity will be necessary, when, and if, it makes sense to convert historical data, and how long forward and backward mapping will be available are all points to consider.

3. Create a documentation improvement plan.

Because of the higher level of specificity required under ICD-10, it is important to ensure the adequacy of clinical documentation to support code assignment under the new system. This can be accomplished by evaluating random samples of medical records to identify areas where documentation is lacking, as well as diagnoses and procedures that will require a higher level of detail. Once documentation deficiencies are identified, you should address any weaknesses and development requirements for monitoring and improving documentation practices. You should implement the plan prior to the transition to ICD-10 and should include ongoing monitoring of the improvement progress. The documentation improvement strategies identified in the assessment can also serve as the foundation of staff educational programs.

4. Assess staff educational needs.

You should conduct a detailed assessment of staff educational needs, budgetary estimates and the timing of educational programs. Because ICD-10 is more granular and detailed, even professional coders and billing specialists who are very comfortable with ICD-9 will require specific training to become proficient with the new diagnostic codes and documentation requirements.

Education cannot focus solely on coding and billing staffs. You will also need to educate the IT staff on the difference between ICD-9 and ICD-10 to determine whether current systems and interfaces should be built or modified in any way. You will need to establish multiple categories of users for identifying the varying levels of education that will be required on the new coding system. Additionally, the organization will need to determine the best method of providing education and the timing of the education for each category of users.

5. Coordinate with business partners.

It is important for providers to sit down with payers early in the process to gain a clear understanding of what they expect under ICD-10, establish when they will be ready to begin receiving claims coded under the new system and determine what, if any, interim plans they have. Organizations that utilize a billing service or clearinghouse, should meet with those vendors to ascertain their plans for rolling out ICD-10 and for supporting the organization during the transition period.

Software vendors may, or may not, be able to provide clients with upgrades that allow them to automatically produce coder-ready documentation appropriate for ICD-10, or to accommodate the dual-coding environment that will likely be  necessary during the early days of deployment. It is important to meet with vendors early in the process to ascertain exactly what role they will play in the transition process, any support they can, or will provide, and any costs for them to do so. Key issues to discuss include vendor readiness and timelines for upgrading software to new coding systems and whether or not upgrades are covered by existing contracts. It will also be necessary to coordinate any software or upgrade installations and testing. Healthcare organizations need to act now to minimize risk and cost, and maximize the opportunities for realizing the efficiencies that ICD-10 ultimately can provide.