ICD-10 action plan-revised
- 1. Large (50+) Practice Implementation A B C D E F G Target Completion 1 Date √ Action Item Considerations Assigned To Progress Reports Date 2 Pre-2010 3 8/31/2009 Organize Implementation 4 Assign two point people within the practice to organize and oversee the 5 implementation plan: one to focus on ICD-10-CM and another person to focus the technical/system implementations of 5010 and system testing The point people will be responsible for addressing key issues and formulating the 6 plan for implementation of their assigned area. Review the 5010 Final Rule: Effective 7 Date 1/1/2012 Review ICD-10 final rule: Effective Date 8 10/1/2013 Identify all areas that will impact the practice such as the clinical areas, IT 9 systems, documentation, payer contracts, policies, reports, etc. Members to consider: managers from billing office, practices, managed care, clinical research, lab, 10 After reviewing the final rule and radiology, pharmacy, medical identifying areas of impact, each point records, IT managers, compliance person will select and appoint members officers and coding/reimbursement to their work group/committee managers If the practice uses a consultant to help 11 with coding or billing issues, invite them to participate with the point people. Prepare briefing materials related to the scope of work that needs to be 12 accomplished for executive leadership review. Meet with physician and executive leadership (executive committee). Medical Director, CEO, COO, 13 Discuss the impact it will have on the CFO/Controller, other executive practice and obtain their support. managers Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 2. Large (50+) Practice Implementation A B C D E F G Establish a timeline and regular schedule 14 to report progress to executive committee. Identify who has final decision making authority and which issues will need 15 executive committee approval (e.g. communications with the physician faculty, budget, funding, contracting, etc) 16 9/1/2009 Establish Communication Plan Establish a communication plan—how the committee and point people will Consider a webpage dedicated to the 17 communicate to all staff in relation to ICD-10 implementation project implementation (e-mail, newsletter, where interested staff can go for meetings, etc.). updates and information Develop materials to disseminate to 18 providers and staff. Begin communication to the entire 19 practice about the ICD-10 implementation efforts Schedule regular meetings with executive Consider adding ICD-10 updates to 20 committee, providers, managers and the agenda of routinely scheduled departments to report progress. department or practice meetings. 21 22 Conduct Impact Analysis / 11/30/2009 Determine Costs Conduct an in-depth impact analysis to identify: 1) resources needed to implement ICD-10-CM ; 2) all systems, 23 policies, forms, and people who will be Consider payer policies, contracts, remotely or directly impacted by ICD-10; forms, systems, training, staffing, and 3) estimate cost for each etc Conduct a review of regulatory requirements at each update (e.g. 24 Oct/Nov 2009) for ICD-10-CM implementation. Identify changes and impact to your plan. Review new coding guidelines and review crosswalks (government crosswalk 25 available; determine if your practice require more enhanced vendor products which will be available at a cost) Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 3. Large (50+) Practice Implementation A B C D E F G Systems might include: practice management systems, billing Review impact on systems within the systems, financial systems, 26 practice on processes and technology. encoders, coding look up programs, Perform an in-depth review of systems claim scrubbing software, electronic that will be affected and prepare a report medical records, electronic for the executive committee. prescription software, PQRI, etc. Access impact to current practice reports/ 27 trending Review vendor contracts: it may be 28 necessary to make amendments and/or updates to these contracts Contact system vendors to identify if the vendors will be able to update software in 29 all needed areas or if new software/hardware will be required. Estimate potential costs. Discuss contracts and if amendment is necessary Vendor testing recommendations (recommend staged testing): get on their 30 schedule NOW. Discuss receiving regular communications about their readiness for October 2013. Contact clearing house to determine how they plan to support transition. Discuss 31 testing, contracting, and on-going communications. Review hardware requirements for new 32 software and identify if hardware needs to be updated or replaced. Conduct a baseline review of current documentation and its impact on ICD-10- CM code selection. (perform audit using Consider ongoing/continued audits 33 ICD-10 codes to identify issues that will as provider education progresses to impact documentation, EMR, policies and ensure improved, detailed medical training) documentation. Assess impact on Standard Operating Procedures, Compliance policies, HIPAA and Security. Review existing operations 34 within the practice and considered areas of improvement—not just meeting the compliance data but developing better operations, performance Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 4. Large (50+) Practice Implementation A B C D E F G Based on audit results, develop documentation improvement guides for 35 providers and clinical staff within the Audit after changes are made and practice. implemented. If introducing an EMR into the practice 36 begin the research and analysis on systems available. 37 Establish a coordination plan for 5010 conversion and/or EMR implementation. Identify requirements for ICD-10-CM education (providers, clinical, 38 administrative, coding and billing). Consider impact on staffing during As assessing, consider and evaluate training sessions. budget costs Review payer contracts and assess 39 possible delayed payments after 10/1/2013. Identify who else needs to help with 40 achieving benefits – vendors, health plans, outside trainers, consultants, etc. 41 12/31/2009 Estimate Budget Estimate costs; identify funding for the 42 project. Consider bake sales ;-) Establish budget and funding approval 43 from executive committee Take cookes ;-) 44 Software 45 Software license 46 Hardware procurement 47 Implementation/Deployment Possible EMR upgrade or new 48 implementation Superbills, lab requistions, lab 49 Forms changes and printing costs orders, treatment orders, etc 50 Staff training (codes and system changes) 51 Coding staff 52 Clinical staff 53 Physicians 54 Billers 55 Referral Coordinators/Financial Counselors 56 Administrative staff Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 5. Large (50+) Practice Implementation A B C D E F G Overtime costs due to training and implementation. Cost of reduced patient 57 schedules during training of providers/staff. Cost of outside resources that may be 58 needed: temporary staffing, training, consultants, etc Cost to maintain CPC certification: 75 questions, computer based test that must be successfully completed to maintain 59 certification with AAPC. Cost of $60 per coder (for 2 tries). Proficiency testing available October 1, 2012 and ends Sept 30, 2014. Workflow process changes /coverage 60 during training 61 Testing 62 Delayed payments 63 Approval of budget Communication of budget plans with 64 physicians or decision maker. Develop an on-going budget re- 65 assessment process. 66 2010 Implementation Planning Coordination of testing, scheduled 67 Determine sequencing of activities (i.e. printing, scheduled computer 7/31/2010 5010 project, EMR implementation). downtime, training, go-live 68 Create a timeline for implementation. The timeline will include key elements for 69 preparedness Timeline should also include metrics to 70 identify if milestone are met. 71 Determine use of crosswalks internally Update current reports/trending that 72 were identified as being impacted by ICD-10 Outline new processes needed because of 73 ICD-10 74 Identify additional quality efforts needed Conduct additional audits and to ensure proper coding specificity review findings 75 Update operation and compliance policies Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 6. Large (50+) Practice Implementation A B C D E F G 76 Update training tools for new providers and staff; as well as other training tools. Review opportunities that could impact 77 reimbursement, value based purchasing, pay for performance and e-prescribing 78 Identify benefits of implementation. 79 Identify how to achieve benefits 80 81 8/31/2010 Contact System Vendors Preliminary assessment of system 82 changes needed for ICD-10. Determine if vendor will support changes 83 to systems. Determine timeline for implementation of 84 changes. Identify other changes to address issues 85 identified in gap analysis. Determine anticipated testing time and 86 schedule (when will they start, how long will they need, and what will be needed for testing (e.g. sample claims). 87 Determine final costs for implementation. 88 Phase I training general overview 89 of ICD-10-CM, guidelines format and structure and Phase II training will 9/30/2010 Two Phase Training Plan be in-depth based on specialty. 90 Identify staff training needs. 91 Clinical staff 92 Coding and billing staff 93 Referral Coordinators or Financial Counselors 94 Administrative staff 95 Physicians 96 Identify resources needed for training: 97 AAPC workshops, audio conferences External training or Physician Specialty Societies Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 7. Large (50+) Practice Implementation A B C D E F G 98 Training materials revised & updated 99 Identify internal resources to support training 100 Purchase of training materials 101 Develop Training Plan. 102 Establish a training schedule Identify materials needed for ongoing 103 support after training Determine if temporary staff is needed during 104 training Develop communication plan for staff on 105 status of training 106 2011 Business Process Analysis Identify all systems and processes that 107 currently use ICD-9 and conclude if they 6/30/2011 need to be upgraded to ICD-10, including: 108 Clinical Administrative (e.g. Practice Mgmt and 109 Registration) Billing (e.g. Computerized systems and 110 Superbills) 111 Other (e.g. Quality and Public Health) Identify limitations in current use of 112 ICD-9-CM, including: Not all diagnosis codes allowed by health 113 plans More patients have complications and 114 comorbidities may require several diagnosis codes to describe their condition Review existing policies and procedures 115 related to ICD-9-CM. Identify any changes needed in existing policy 116 and procedures, including: 117 - ICD-9-CM reporting 118 - Auditing of clinical documentation - Review of specific clinical events – 119 adverse events Identify impact to reports involving 120 ICD-10, including: 121 Internal 122 - Quality improvement Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 8. Large (50+) Practice Implementation A B C D E F G 123 External 124 - Federal 125 Adverse drug events 126 Medical devices 127 Pay for performance 128 Research 129 - State 130 Public health 131 Newborn screening Identify impact of ICD-10 on 132 payer/health plan contracts. Identify contracts where reimbursement is tied 133 to particular diagnoses Contact payers and discuss potential changes 134 to existing contracts 135 Determine timing of contract negotiations 136 Modify agreements as needed Communicate contract changes to appropriate 137 staff Conduct a gap analysis to determine 138 specific areas to improve/update. Monitor payer policies (eg NCD and LCD 139 coverage changes) Establish a plan for possible delayed 140 payments after go-live Oct 1, 2013. 141 142 143 2012 Phase I Training 144 9/30/2012 Begin Phase I training for: 145 Coding and billing staff 146 Physicians and other practitioners 147 Clinical Staff 148 Administrative Staff 149 Managerial Staff 150 Begin Phase I general training including: 151 Audio conferences 152 AAPC Local, Regional & Nat'l Meetings 153 Web portal training Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 9. Large (50+) Practice Implementation A B C D E F G 154 Workshops and webcasts 155 Distance Learning 156 157 2013 Phase II Training Begin Phase II of specialty specific 158 9/30/2013 training including: 159 Audio conferences 160 AAPC Local & Regional Conferences 161 AAPC National Conference 162 Workshops & webcasts 163 Distance Learning 164 Specialty Specific Training Sessions 165 Web portal training 166 Training Should include: 167 Coding and billing staff 168 Physicians and other practitioners 169 Clinical Staff 170 Administrative Staff 171 Managerial Staff Certified Coders take AAPC Proficiency 172 Test to maintain certification. $60 per coder (2 tries to pass) 173 174 Deployment of Code by Vendors 5/31/2013 to Customers Integrate software program(s) into your 175 systems. Make internal customization after 176 deployment of code by vendor. Integrate changes into production 177 systems. Test systems with clearinghouses, payers, electronic claims transmission with each 178 individual system (end to end). Finalizing testing process. Ensure vendors will maintain updates to 179 code during transition period. 180 181 8/31/2013 Outcomes Measurement Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 10. Large (50+) Practice Implementation A B C D E F G Measure coder productivity when using 182 ICD-10-CM. Re-evaluate the medical record 183 documentation to ensure ICD-10-CM coding can be achieved. Internal testing of coding and billing staff 184 in ICD-10-CM proficiency. Provide additional education and training 185 if deficiencies are identified. 186 187 2014 Implementation Compliance 188 9/30/2014 October 1, 2013 -“GO Live”. 189 Resolution of claim errors and denials. Review insurance carrier payment 190 policies. Conduct medical record documentation 191 reassessment. Measure training and productivity 192 outcomes. 193 Provide retraining when needed. Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders
- 11. Medium (11-49) Practice Implementation Target Date P Action Item Considerations Assigned To Progress Reports Completion Date Pre-2010 Organize the Implementation Effort 9/30/2009 Review ICD-10 Final Rule Senior management briefing and organization buy-in Complete preliminary analysis of system impact Prepare briefing materials for providers and staff to review related to the work and scope of work that needs to be accomplished Identify senior manager project supporter Establish senior management’s role in completing project Obtain support from all providers and senior management Talk with providers about ICD-10-CM and the impact it will have on the practice Identify all areas that will impact the practice such as the clinical areas, systems, documentation etc, and share this information with providers Establish regular schedule to report progress to senior management Coordinate briefing with the ICD-10 5010 project team 10/31/2009 Develop Communication Plan Develop materials to disseminate to managers, staff and providers Include preliminary information on timeframe and training Conduct periodic briefings for staff or include information in other briefing/communication formats (i.e. newsletters, e-mails, etc). 2010 5/31/2010 Conduct Impact Analysis
- 12. Medium (11-49) Practice Implementation This is an in-depth impact analysis to identify resources needed to implement ICD-10-CM which should include Conduct a review of regulatory requirements for ICD-10-CM implementation Identify at a high level existing systems processes and technology that will be impacted by ICD-10-CM Determine requirements and educational expectations by Departments Users Systems, including internal and external vendor information systems Contact system vendors to identify if the vendors will be able to update software in all needed areas with potential costs Review hardware requirements for new software and identify if hardware needs to be updated or replaced Identify funding for the project Identify project manager Establish approval from management or providers Determine sequencing of activities (i.e. 5010 project, EMR implementation). Coordinate with 5010 project team Coordinate with EMR implementation project team Review existing operations within the practice and consider areas of improvement—not just meeting the compliance data but developing better operations, performance, quality, etc. Create a timeline for implementation. The timeline will include key elements for preparedness Timeline should also include metrics to identify if milestone are met
- 13. Medium (11-49) Practice Implementation 8/31/2010 Contact System Vendors Preliminary assessment of system changes needed for ICD-10-CM conversion Determine if vendor will support changes to systems Determine timeline for implementation of changes Determine final costs for implementation Identify other changes to address issues identified in gap analysis Identify when testing will occur Determine anticipated testing time and schedule (when will they start, how long will they need, and what will be needed for testing (e.g. sample claims)). 2011 8/31/2011 Implementation Planning Identify overall impact of ICD-10-CM. Review the new coding guidelines. Identify general impact of coding changes Review crosswalks – government available; more enhanced vendor products Determine use of crosswalks internally Identify changes to current reports/trending involving ICD-10 Identify any new processes needed because of ICD-10 Identify additional quality efforts needed to ensure proper coding specificity Review opportunities that could impact reimbursement, value based purchasing, and pay for performance. Identify benefits of implementation
- 14. Medium (11-49) Practice Implementation Identify specific benefits Identify how to achieve benefits Identify who else needs to help with achieving benefits – vendors, health plans, etc. 2012 9/30/2012 Phase I Training Begin Phase I training for Senior management Cross functional teams Coding and billing staff Physicians and other practitioners Clinical Staff Administrative Staff Phase I general training may include Audio conferences Local AAPC Chapter and AAPC Regional Conferences AAPC National Conference Workshops Distance Learning AAPC Curriculum 8/31/2012 Business Process Analysis Identify all systems and processes that currently use ICD-9-CM and conclude if they need to be upgraded to ICD-10-CM, including Clinical (e.g. Laboratory and Radiology) Administrative (e.g. Practice Management and Registration) Billing (e.g. Computerized systems and Superbills) Other (e.g. Quality and Public Health) Identify limitations in current use of ICD-9-CM, including
- 15. Medium (11-49) Practice Implementation Not all diagnosis codes allowed by health plans More patients have complications and comorbidities may require several diagnosis codes to describe their condition Review existing policies and procedures related to ICD-9-CM. Identify any changes needed in existing policy and procedures, including ICD-9-CM reporting Auditing of clinical documentation Review of specific clinical events – adverse events Identify impact to reports involving ICD-10-CM, including: Internal-Quality Improvement External-Federal Adverse drug events Medical devices Pay for performance Research External-State Public health Newborn screening Identify impact of ICD-10 on payer/health plan contracts Identify contracts where reimbursement is tied to particular diagnoses Contact payers and discuss potential changes to existing contracts Determine timing of contract negotiations Modify agreements as needed Communicate contract changes to appropriate staff Conduct a gap analysis to determine specific areas to improve/update 2013
- 16. Medium (11-49) Practice Implementation 9/30/2013 Education and Training, Phase II Begin Phase II of specialty specific training including Audio conferences Local AAPC Chapter and AAPC Regional Conferences AAPC National Conference Workshops Distance Learning Specialty Specific Training Sessions Training Should include Coding and billing staff Physicians and other practitioners Clinical Staff Administrative Staff Managerial Staff Take AAPC Proficiency Test to maintain certification 4/30/2013 Policy Change Development Identify opportunities to improve processes Make changes to policies as identified in the gap analysis Obtain approval from appropriate source(s) for policy changes Educate staff and physicians on policy changes 8/31/2013 Outcomes Measurement Measure coder productivity when using ICD-10-CM Re-evaluate the medical record documentation to ensure ICD-10-CM coding can be achieved. Internal testing of coding and billing staff in ICD-10-CM proficiency
- 17. Medium (11-49) Practice Implementation Provide additional education and training if deficiencies are identified Deployment of Code by Vendors to 5/31/2013 Customers Integrate software program(s) into your systems Make internal customization after deployment of code by vendor Integrate changes into production systems Test systems with clearinghouses, payers, electronic claims transmission with each individual system (end to end). Ensure vendors will maintain updates to code during transition period 2014 9/30/2014 Implementation Compliance October 1, 2013 -“GO Live”. Resolution of claim errors and denials Review insurance carrier payment policies Conduct medical record documentation re-assessment Measure training and productivity outcomes Provide retraining when needed
- 18. Small (4-10) Practice Implementation Target Date Action Item Assigned To Progress Reports/Comments Completion Date Pre-2010 Organize Implementation Create a point person within the practice to organize and oversee ICD-10-CM 7/31/2009 implementation. The point person will be responsible for addressing key issues and formulate the plan for implementation. Prepare briefing materials for providers and staff to review related to the work and scope of work that needs to be accomplished. If the practice uses a consultant to help with coding or billing issues, invite them to participate with the point person. Obtain support from all providers. Talk with providers about ICD-10 and the impact it will have on the practice. Establish a timeline and regular schedule to report progress to providers. Schedule meetings with providers or managers on a regular basis at a minimum monthly to report progress. Identify all areas that will impact the practice such as the clinical areas, IT systems, documentation etc., and share this information with providers. Identify who has final decision making authority Establish Communication 8/31/2009 Plan
- 19. Small (4-10) Practice Implementation Establish a communication plan —how the committee or point person will communicate to all staff in relation to implementation (e-mail, newsletter, meetings, etc.). Develop materials to disseminate to providers and staff. 11/30/2009 Conduct Impact Analysis This is an in-depth impact analysis to identify resources needed to implement ICD-10- CM which should include: Conduct a review of regulatory requirements for ICD-10-CM implementation. Review impact on systems within the practice on processes and technology. Perform an in-depth review of systems that will be affected and prepare a report for the provider. Systems might include: practice management systems, billing systems, financial systems, encoders, coding look up programs, electronic medical records, etc. Contact system vendors to identify if the vendors will be able to update software in all needed areas with potential costs. Review hardware requirements for new software and identify if hardware needs to be updated or replaced.
- 20. Small (4-10) Practice Implementation Conduct a review of current documentation and its impact on ICD-10-CM code selection. Based on audit results, develop documentation improvement guides for providers within the practice. Identify funding for the project. Establish approval from management or providers. Determine sequencing of activities (i.e. 5010 project, EMR implementation). If using a practice management system that transmits electronic claims, contact the vendor for an update on how they will support transition. If introducing an EMR into the practice begin the research and analysis on systems available. Establish a coordination plan for 5010 conversion and/or EMR implementation. Identify requirements for ICD-10-CM education (providers, clinical, administrative, coding and billing). Review existing operations within the practice and considered areas of improvement—not just meeting the compliance data but developing better operations, performance, quality, etc. Create a timeline for implementation. The timeline will include key elements for preparedness Timeline should also include metrics to identify if milestone are met.
- 21. Small (4-10) Practice Implementation 12/31/2009 Estimate Budget The budget should include all costs associated with implementation including: Software Software license Hardware procurement Implementation/Deployment Possible EMR upgrade or new implementation Staff training Coding staff Clinical staff Physicians Administrative staff Overtime costs due to training and implementation Workflow process changes Testing Communication of budget plans with physicians or decision maker. Develop an on-going budget re-assessment process. 2010 7/31/2010 Implementation Planning Identify overall impact of ICD-10- CM. Review the new coding guidelines Identify general impact of coding changes Review crosswalks – government available; more enhanced vendor products Determine use of crosswalks internally
- 22. Small (4-10) Practice Implementation Identify changes to current reports/trending involving ICD-10 Identify any new processes needed because of ICD-10 Identify additional quality efforts needed to ensure proper coding specificity Review opportunities that could impact reimbursement, value based purchasing, and pay for performance Identify benefits of implementation. Identify specific benefits Identify how to achieve benefits Identify who else needs to help with achieving benefits – vendors, health plans, etc. 8/31/2010 Contact System Vendors Preliminary assessment of system changes needed for ICD-10. Determine if vendor will support changes to systems. Determine timeline for implementation of changes. Determine final costs for implementation. Identify other changes to address issues identified in gap analysis. Identify when testing will occur. Determine anticipated testing time and schedule (when will they start, how long will they need, and what will be needed for testing (e.g. sample claims)).
- 23. Small (4-10) Practice Implementation Development of the 9/30/2010 Training Plan Identify staff training needs. Identify resources needed for training: External training Training materials Internal resources available to support training Coordinate internal training Phase I training general overview of ICD-10-CM, guidelines format and structure and Phase II training will be in-depth based on specialty. Clinical staff Coding and billing staff Administrative staff Physicians Develop Training Plan. Establish a training schedule Identify materials needed for ongoing support after training Determine if temporary staff is needed during training Develop communication plan for staff on status of training 2011 6/30/2011 Business Process Analysis 1. Identify all systems and processes that currently use ICD-9 and conclude if they need to be upgraded to ICD-10, including: Clinical
- 24. Small (4-10) Practice Implementation Administrative (e.g. Practice Management and Registration) Billing (e.g. Computerized systems and Superbills) Other (e.g. Quality and Public Health) Identify limitations in current use of ICD-9-CM, including: Not all diagnosis codes allowed by health plans More patients have complications and comorbidities may require several diagnosis codes to describe their condition Review existing policies and procedures related to ICD-9- CM. Identify any changes needed in existing policy and procedures, including: ICD-9-CM reporting Auditing of clinical documentation Review of specific clinical events – adverse events Identify impact to reports involving ICD-10, including: Internal Quality improvement External-Federal Adverse drug events Medical devices Pay for performance Research External-State Public health Newborn screening Identify impact of ICD-10 on payer/health plan contracts. Identify contracts where reimbursement is tied to particular diagnoses
- 25. Small (4-10) Practice Implementation Contact payers and discuss potential changes to existing contracts Determine timing of contract negotiations Modify agreements as needed Communicate contract changes to appropriate staff Conduct a gap analysis to determine specific areas to improve/update. 2012 Policy Change 6/30/2012 Development Identify opprotunities to improve processes and make changes to policies identified in 6.5 Obtain approval from appropriate sources for policy change Educate staff and physicians on policy changes 2013 8/31/2013 Outcomes Measurement Measure coder productivity when using ICD-10-CM. Re-evaluate the medical record documentation to ensure ICD-10-CM coding can be achieved. Internal testing of coding and billing staff in ICD-10-CM proficiency. Provide additional education and training if deficiencies are identified.
- 26. Small (4-10) Practice Implementation Education and Training, 9/30/2013 Phase II Begin Phase II of specialty specific training including: Audio conferences Local chapter and AAPC Regional Conferences AAPC National Conference Workshops Distance Learning Specialty Specific Training Sessions Training Should include: Coding and billing staff Physicians and other practitioners Clinical Staff Administrative Staff Managerial Staff Take AAPC Proficiency Test to maintain certification. 2014 Implementation 9/30/2014 Compliance October 1, 2013 -“GO Live”. Resolution of claim errors and denials. Review insurance carrier payment policies. Conduct medical record documentation re-assessment. Measure training and productivity outcomes. Provide retraining when needed.
- 27. Very Small (1-3) Practice Implementation Target Date P Action Item Considerations Assigned To Progress Reports Completion Date Pre-2010 Organize Implementation 7/31/2009 Review ICD-10 Final Rule Create a point person within the practice to organize and oversee ICD-10-CM implementation. The point person will be responsible for addressing key issues and formulate the plan for implementation. Prepare briefing materials for providers and staff to review related to the work and scope of work that needs to be accomplished If the practice uses a consultant to help with coding or billing issues, invite them to participate with the point person. Obtain support from all providers. Talk with providers about ICD-10 and the impact it will have on the practice Establish a timeline and regular schedule to report progress to providers Schedule meetings with providers on a regular basis at a minimum monthly to report progress Identify all areas that will impact the practice such as the clinical areas, IT systems, documentation etc,, and share this information with providers Identify who has final decision making authority 8/31/2009 Establish Communication Plan Establish a communication plan—how the committee or point person will communicate to all staff in relation to implementation (e-mail, meetings, etc.). Develop materials to disseminate to providers and staff
- 28. Very Small (1-3) Practice Implementation 11/30/2009 Conduct Impact Analysis This is an in-depth impact analysis to identify resources needed to implement ICD-10-CM which should include Conduct a review of regulatory requirements for ICD-10-CM implementation Review impact on systems within the practice including processes and technology. Perform an in-depth review of systems that will be affected and prepare a report for the provider. Systems might include: practice management systems, billing systems, financial systems, encoders, coding look up programs, electronic medical records, etc. Contact system vendors to identify if the vendors will be able to update software in all needed areas with potential costs Review hardware requirements for new software and identify if hardware needs to be updated or replaced Conduct a review of current documentation and its impact on ICD-10-CM code selection Based on audit results, develop documentation improvement guides for providers within the practice Identify funding for the project Establish approval from providers. Determine sequencing of activities (i.e. 5010 project, EMR implementation). If using a practice management system that transmits electronic claims, contact the vendor for an update on how they will support the transition If introducing an EMR into the practice begin the research and analysis on systems available
- 29. Very Small (1-3) Practice Implementation Establish a coordination plan for 5010 conversion and/or EMR implementation. Identify requirements for ICD-10-CM education (providers, clinical, administrative, coding and billing). Review existing operations within the practice and considered areas of improvement—not just meeting the compliance data but developing better operations, performance, quality, etc. Create a timeline for implementation The timeline will include key elements for preparedness Timeline should also include metrics to identify if milestone are met 12/31/2009 Estimate Budget The budget should include all costs associated with implementation including Software Software license Hardware procurement Implementation/Deployment Possible EMR upgrade or new implementation Staff training Coding staff Clinical staff Physicians Administrative staff including front office staff Overtime costs due to training and implementation Workflow process changes Testing Communication of budget plans with physicians or decision maker
- 30. Very Small (1-3) Practice Implementation Develop an on-going budget re- assessment process 2010 5/31/2010 Implementation Planning Identify overall impact of ICD-10-CM Review the new coding guidelines Identify general impact of coding changes Review crosswalks – government available; more enhanced vendor products Determine use of crosswalks internally Identify changes to current reports/trending involving ICD-10 Identify any new processes needed because of ICD-10 Identify additional quality efforts needed to ensure proper coding specificity Review opportunities that could impact reimbursement, value based purchasing, and pay for performance Identify benefits of implementation Identify specific benefits Identify how to achieve benefits Identify who else needs to help with achieving benefits – vendors, health plans, etc 6/30/2010 Contact System Vendors Preliminary assessment of system changes needed for ICD-10 Determine if vendor will support changes to systems Determine timeline for implementation of changes. Determine final costs for implementation Identify other changes to address with vendor including issues identified in gap analysis
- 31. Very Small (1-3) Practice Implementation Identify when testing will occur Determine anticipated testing time and schedule (when will they start, how long will they need, and what will be needed for testing (e.g. sample claims)). 6/30/2010 Development of the Training Plan Identify staff training needs. Identify resources needed for training External training Training materials Internal resources available to support training Coordinate internal training Phase I training general overview of ICD-10-CM, guidelines format and structure. Clinical staff Coding and billing staff Administrative staff including front office staff Physicians Phase II training will be in-depth based on specialty Coding and billing staff Clinical Staff (if applicable) Physicians Develop Training Plan Establish a training schedule Identify materials needed for ongoing support after training Determine if temporary staff is needed during training Develop communication plan for staff on status of training 2011 1/31/2011 Business Process Analysis
- 32. Very Small (1-3) Practice Implementation Identify all systems and processes that currently use ICD-9 and conclude if they need to be upgraded to ICD-10, including: Clinical Administrative (e.g. Practice Management and Registration) Billing (e.g. Computerized systems and Superbills) Other (e.g. Quality and Public Health) Identify limitations in current use of ICD-9-CM, including Not all diagnosis codes allowed by health plans More patients have complications and comorbidities may require several diagnosis codes to describe their condition Review existing policies and procedures related to ICD-9-CM. Identify any changes needed in existing policy and procedures, including: ICD-9-CM reporting Auditing of clinical documentation Review of specific clinical events – adverse events Identify impact to reports involving ICD-10, including: Internal Quality improvement External Federal Adverse drug events Medical devices Pay for performance Research State Public health Newborn screening Identify impact of ICD-10 on payer/health plan contracts
- 33. Very Small (1-3) Practice Implementation Identify contracts where reimbursement is tied to particular diagnoses Contact payers and discuss potential changes to existing contracts Determine timing of contract negotiations Modify agreements as needed Communicate contract changes to appropriate staff Conduct a gap analysis to determine specific areas to improve/update 2012 09/30/212 Phase I Training Begin Phase I training for Coding and billing staff Physicians and other practitioners Clinical Staff Administrative Staff Managerial Staff Begin Phase I general training including Audio conferences Local AAPC Chapter and AAPC Regional Conferences AAPC National Conference Workshops Distance Learning AAPC Curriculum 6/30/2012 Policy Change Development Identify opportunities to improve processes Make changes to policies as identified in the gap analysis Obtain approval from appropriate source(s) for policy changes
- 34. Very Small (1-3) Practice Implementation Educate staff and physicians on policy changes 2013 Deployment of Code by Vendors to 5/31/2013 Customers Integrate software program(s) into your systems. Make internal customization after deployment of code by vendor Integrate changes into production systems Test systems with clearinghouses, payers, electronic claims transmission with each individual system (end to end). Ensure vendors will maintain updates to code during transition period 8/31/2013 Outcomes Measurement Measure coder productivity when using ICD-10-CM Re-evaluate the medical record documentation to ensure ICD-10-CM coding can be achieved Internal testing of coding and billing staff in ICD-10-CM proficiency Provide additional education and training if deficiencies are identified 9/30/2013 Education and Training, Phase II Begin Phase II of specialty specific training including: Audio conferences Local chapter and AAPC Regional Conferences AAPC National Conference Workshops
- 35. Very Small (1-3) Practice Implementation Distance Learning Specialty Specific Training Sessions Training Should include: Coding and billing staff Physicians and other practitioners Clinical Staff Administrative Staff Managerial Staff Take AAPC Proficiency Test to maintain certification. 2014 9/30/2014 Implementation Compliance October 1, 2013 -“GO Live”. Resolution of claim errors and denials Review insurance carrier payment policies Conduct medical record documentation re-assessment Measure training and productivity outcomes Provide retraining when needed
- 36. Compatibility Report for Latest Copy of ICD-10 ACTION PLAN-REVISED.xls Run on 8/24/2009 13:47 The following features in this workbook are not supported by earlier versions of Excel. These features may be lost or degraded when you save this workbook in an earlier file format. Minor loss of fidelity # of occurrences Some cells or styles in this workbook contain formatting that is not supported 6 by the selected file format. These formats will be converted to the closest format available.