WEDI ICD-10 Progress Survey August 2011

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1 WEDI ICD-10 Progress Survey August 2011 What are some of the key findings/learnings you identified as part of your Impact Assessment? Response Count 9 answered question 9 skipped question 286 Page 4, Q6. What are some of the key findings/learnings you identified as part of your Impact Assessment? 1 Since the ICD-10 regulation is Date of Service or Discharge Date driven, all constituents must be prepared to use both 9 and 10 codes for an undetermined period of time. Overall, the organization needs additional ICD-10 training to increase understanding of impacts on people, process and technology and impacts for customers. Most constituents see the benefit of a code transformation tool to aid in understanding how current ICD-9 codes relate to new ICD-10 codes for implementation purposes. Contingency planning and implementation flexibility across the enterprise will be key if customers are not prepared for the compliance direction changes. 2 Our hospital clients are still very engaged in v5010 EDI migration and very few have begun to think in detail about the operational impacts of moving to I-10. It's not something, with a few exceptions, high on their short list of projects with the exception of the HIM area. Aug 31, :11 AM Aug 31, :17 AM 3 That more than 50% of our customers are not ready to deal with ICD-10. Aug 29, :43 PM 4 Payers expect that providers will bill incorrectly either by mixing ICD-9 and ICD- 10 or using the wronig code set based on compliance date. Clients expect to have tools (crosswalks, gems) to be able to resolve coding issues. Clients also expect ability to reject back to providers. Primary use of ICD codes outside of our bill review softare is the medicare reporting MMSEA 111 reporting. Some human decison making around ICD codes.. Very little automated decisoin making around ICD codes. 5 Not knowing if all payers will be ready on What happens if a payer is not ready, how will the vendor handle sneding ICD-9 codes Each patient/diagnosis will need to be individually evaluated. 2. We cannot create a systemic conversion from ICD-9 to ICD as a product we are ahead of our third party product partners. 2. Due to other priorities, our clients were not as focused on ICD10 as we were, when we were developing our solution. As a result, we had limited input from our clients. 3. Aug 29, :41 PM Aug 22, :04 AM Aug 17, :08 PM Aug 16, :31 AM 1 of 2

2 Page 4, Q6. What are some of the key findings/learnings you identified as part of your Impact Assessment? Our solution includes a 'back conversion', based on the ICD10 to ICD9 Reimbursement mappings (CMS). The back conversion functionality requires heavy configuration involvement for each client. We anticipate a need to provide additional consulting services to our clients and may need to incorporate some additional changes. 8 Many providers are not focused on ICD-10 to the extent they should be due to other projects with due dates occurring sooner than 10/1/2013 compliance date. 9 The process of coders learning ICD-10 selection when they have been so familiar with ICD-9 (Appears that it is more or less a learning curve issue more than anything) Aug 11, :44 PM Aug 8, :16 PM 2 of 2

3 WEDI ICD-10 Progress Survey August 2011 What are some of the key findings/learnings you identified as part of your Impact Assessment? Response Count 50 answered question 50 skipped question 245 Page 9, Q6. What are some of the key findings/learnings you identified as part of your Impact Assessment? 1 Still TBD Aug 31, :10 PM 2 Training needs high level of attention In House systems/customization review Aug 31, :48 PM 3 Nearly all areas of our organization are impacted We have opportunities to innovate for operational effectiveness Physicians need enabling technology - Encounter forms and code selection can no longer be a manual process A major challenge in this remediation effort is that there is not a mandated or sufficient crosswalk/mapping/translation Providers' ability to successfully migrate is dependent on many things out of their control (vendor and payer readiness, dual processing capabilities, physician adoption, quality of clinical documentation, etc.) Lack of incentive for physicians to endure the expense and pain of migrating Hospitals need support from professional organizations (AMA, AHA, American Colleges, etc.) Aug 30, :36 PM 4 Extent of impact Dependency on vendors to complete their changes. Aug 30, :53 PM 5 1. There is not one consistant solution. Each vendor has a different approach and timeline to complete their ICD-10 readiness. 2. There are many internal processes that will be impacted. 3. Training needs will vary greatly based on role. 4. Integrated test environments will be needed for nearly all systems in order to conduct end to end testing (scheduling, service, documentation, billing, payers). This will be difficult to achieve based on the varied timelines of the vendors involved. 6 This project will require significant project management and change management rigor. Without that rigor we will experience a significant decrease in revenue. 7 Many systems and ad hoc reports impacted Training will be extensive and it will be difficult to capture the attention of MDs to get their documentation to the level needed for ICD10 coding Several payer contracts will need to be amended to change carve outs to ICD10. Aug 30, :22 AM Aug 30, :55 AM Aug 29, :56 PM 1 of 4

4 Page 9, Q6. What are some of the key findings/learnings you identified as part of your Impact Assessment? 8 We just developed the assessment and have not distributed it yet. Aug 29, :21 PM 9 There are more reports that contain ICD-9 data than anticipated. There are areas that will need ICD-10 awareness training Our corporated coding dept is well prepared for the transition 10 Some system impacts but they are manageable. The majority of impacts will be business related and more difficult to resolve. 11 More systems using ICD-9 than expected More internal codes built in (EPIC) than expected Conflicting opinions about when to train coders 12 Significant training requirements. Vendor remediation readiness monitoring required. Monitoring reimbursement and billing delays. 13 Some vendors will be ready earlier than others. Those that are late will severely impact our ability to conduct integrated testing. The ability to manage both ICD- 9 and ICD-10 data for Problem lists, analysis, trends, etc. is a major challenge, that no vendor system appears to have a viable solution. Opportunity to replace manual processes, but concern that vendor solutions used will be inadequate to our needs. Getting a plan in place at the enterprise level is difficult, despite highlevel attention and high risks. 14 Most vendors have not committed to any software upgrades and/or delivery dates. We would have expected more clear timelines at this point. We are concerned there may be additional software costs (above 'normal' maintnance costs). At this point, we would have expected vendor to include in maintenance or disclose additional costs, so they can be budgeted. Aug 29, :12 PM Aug 29, :57 PM Aug 29, :31 PM Aug 29, :13 PM Aug 29, :35 AM Aug 24, :34 PM 15 Everyone is affected! Aug 23, :55 PM 16 Time constraints, budget identification issues and over all there is a lot of work and planning taht is taking place and will need to continue thru to October Impact Assessment took longer than expected. 17 Not all business areas were using same reference source for ICD codes and descriptions. 18 volume of users impacted is well beyond HIM; training will be critical and will need to begin as early as 2012 for some groups; some software remediation will need to be available one year in advance for preparatory work to ensure tools/resources are available for users, e.g. encounter forms/superbill changes, chargemaster updates, documentation templates, etc. Aug 22, :57 PM Aug 22, :22 AM Aug 22, :25 AM 19 Providers are hightly skilled in IT systems Aug 20, :48 PM 20 Training needs/impact Clinical documentation impact ICD9 usage within processes 21 Vendors are very late with delivering application upgrades- some don't even have a strategy/plan or date yet. Not having a national crosswalk standard is a serious issue. Not a surprise- Physician Clinical Documentation is at the heart of ICD-10 and needs to be electronic to be really successful. CAC will help with coder productivity. Aug 18, :35 AM Aug 18, :19 AM 22 We are a Home Infusion Therapy provider. Our patients are discharged from an Aug 17, :49 PM 2 of 4

5 Page 9, Q6. What are some of the key findings/learnings you identified as part of your Impact Assessment? inpatient stay or an outpatient visit when they start on service with us. They already have ICD's assigned from either of those facilities. We need to be able to review those and make sure they make sense for our therapies. 23 Impact on reimbursement Aug 17, :11 PM 24 Reporting from our Data Warehouse will be a much greater impact than we realized at the beginning. Training for analysts is going to be much larger than anticipated. Training for the physicians, while we anticipated the difficulty, will be significant. Aug 17, :06 PM 25 Not completed yet Aug 17, :12 AM 26 What is an Impact Assessment? Aug 16, :15 PM 27 Not yet complete Aug 14, :10 PM 28 Unknown Aug 14, :39 AM 29 W Aug 13, :13 AM 30 Impact appears to be more than normal (industry standard) education for our providers since they are responsible for coding charges. 31 For a solo practicioner such as myself, this appears overwhelming, unobtainable, and not affordable Very large enterprise wide project 2.Training effort will be substantial 3.Significant number of resources will be required (operational & technical) to address this effort 4.Trading Partner testing will require a very large effort 5.Trading Partner/Industry readiness is a very big concern Aug 12, :48 PM Aug 12, :39 PM Aug 12, :38 PM 33 I am probably going to close down. Aug 12, :29 PM 34 waste if time costly more overhead Aug 12, :36 AM 35 physician documentation will be very important for inpatient and OUTPATIENT services, how will we get their buy-in and compliance? Aug 11, :46 PM 36 Intitially it slows the practice way down. Aug 11, :58 PM 37 this doesn't start till Oct of 2013 SO WHO CARES Aug 11, :18 PM 38 billing program and clearinghouse are not ready to talk yet even. Aug 11, :17 PM 39 ICD-10 implementation and new HIS system implementation dates are impacting all work flow. Vendors have been slow to respond to their status in the ICD-10 conversion. We have many more systems that will be impacted by ICD-10 than we realized. 40 Vendor Management: Who owns the product now is not necessarily who owned the product when you purchased it. 41 My assessment of ICD-10 transition is straightforward but extremely concerning. The transition as currently designed should be relatively easy for coders, billing departments, and office staff. However, current preparations and training appear Aug 11, :32 AM Aug 11, :47 AM Aug 10, :37 PM 3 of 4

6 Page 9, Q6. What are some of the key findings/learnings you identified as part of your Impact Assessment? to be completely inadequate for physicians. It is clear that ICD-10 codes must be identified at the point of care, but unless each physician has a certified coder involved in every patient encounter (an economic impossibility), the current system does not provide for correct code selection by the physician at the point of care (too many choices for accurate coding by conventional superbill or by extensive drop down menus on a computer screen). I have actually developed some sophisticated superbill templates that would work for most codes (except the circumstances discussed next), but no one appears yet to be paying any attention to this issue. Further, some of the new documentation requirements (e.g., for trauma circumstances) are not compatible with medically appropriate physician documentation. The bottom line: CMS or others need to develop solutions that will work for physicians in the real world, or this implementation will either 1) fail completely, or 2) it will result in MDs just using limited superbills with only non-specific codes that will essentially give little more information than ICD- 9 codes. But unless someone develops solutions that work for physicians at the point of care, this program will expend great cost and effort with very little gain. Note: I have discussed this issue with some of the national leaders in ICD-10 coding, and none of them have been able to conceive of a solution to this issue 42 The most surprising finding was how many departments had paper forms that contained ICD-9 codes. 43 To Date: 1-Inadequate physician documentation 2-EMR limitations 3-Limited coding resources 4-Payer unpreparedness 5-IT systems inventory show less than national average requiring replacement/upgrades 44 need for increased physician documentation need for software updates throughout many platforms need to educate physician offices Aug 10, :41 PM Aug 10, :22 PM Aug 10, :22 PM 45 not started Aug 10, :08 PM 46 In progress Aug 10, :52 PM 47 We have not completed an assessment. we are just beginning to work on this. Aug 10, :14 PM 48 N/A (Impact Assessment not completed to date) Aug 9, :56 PM 49 lack of vendor readiness Aug 8, :48 PM 50 ICD-9 codes have a very broad depth and breadth in organizations. ICD-10 will have the same Aug 8, :25 PM 4 of 4

7 WEDI ICD-10 Progress Survey August 2011 What are some of the key findings/learnings you identified as part of your Impact Assessment? Response Count 35 answered question 35 skipped question 260 Page 7, Q12. What are some of the key findings/learnings you identified as part of your Impact Assessment? 1 It was a great tool to clarify what ICD10 is for a lot of areas. It was an eye-opener for areas that did not believed they would be impacted. Most people only thought of ICD10 impacts as they related to the codes themselves, the learning was: if you use diagnosis descriptions or any form of grouping (based on code or description) you will be impacted too. 2 1) Based on gaps discovered, the State Plan may require updates to ICD-10 related expenditures through a State Plan Amendment (SPA). 2) Impacts to State Administrative Code: two main types of changes should be made to the IAC: - Change version-specific references and replace with most current version reference for ICD and DSM. - Remove code-specific references and incorporate by reference. 3) Rates and Fee Schedules are impacted: Medicaid Outpatient Code Editor (OCE) edits were identified as being diagnosis-based; obvious impacts to DRGs and decisions need to be made as to what version the State goes with. 4) Impacts to Contracts identified were primarily related to inclusionary and exclusionary language to diagnosis and ICD procedure codes. 5) Impacts to Provider Manuals, Employee Manuals, and Business Process were identified (primary business process impacts in Operations Management and Program Integrity Management Business Areas). 3 - Crosswalk would not result in an exact match. - Some changes will be determined based on any change in medical policy Heavy business process impact 2. Financial Neutrality strategy will be required 3. Significant communication, education and training will be required to be successful 4. Significant time and resources will be required for testing. 5 The major impact is to our Medical Management areas, which include Medical Policy, Medical Review, Case Management, Disease Management etc. Then to our Provider Relations area due to the impact on the provider community. There is IS impact, but not as significant. Aug 31, :37 PM Aug 31, :59 AM Aug 31, :37 AM Aug 31, :19 AM Aug 31, :13 AM 6 GEMS has been useful in mapping. DM/UM impacts are complex. Aug 30, :23 PM 1 of 4

8 Page 7, Q12. What are some of the key findings/learnings you identified as part of your Impact Assessment? 7 1) Identified and prioritized areas with higher impacts 2) Developed a planning estimate for costs related to implementation of ICD-10 8 Dependencies on Claims systems, Data Analytics impacts with transiting to new codesets and working with old codesets. 9 Departments aren't clear where ICD codes truly impact them. We've seen a lot of complacence around "this won't affect me", but upon further questioning, they realize that they do have systems or processes that will need to change. Crosswalking or translation was assumed to be able to handle all situations. As we've begun mapping out how each type of provider claim would be processed through a translation, we've realized that we aren't going to be able to autotranslate 100% of claims. We will need to deny some claims. We don't have a good plan for identifying and handling non-covered entity claims. 10 WellPoint s key findings to our Impact Assessment include: Substantially all systems and processes need to be examined/updated Provider and External Partner readiness are significant dependencies for the industry Internal retraining and education is a significant effort ICD-10 presents opportunities to create process and technology efficiencies Aug 29, :26 PM Aug 29, :52 AM Aug 29, :12 AM Aug 25, :14 PM 11 We believe full remediation is achievable by October 1, 2013 Aug 25, :35 AM 12 Use of a crosswalk for operational / transactional processes has been ruled out due to the risk and complexity. Systems will be enhanced to process ICD-10 natively. 13 1) Significant testing to EDI system 2) Data interface points should be a priority focus 3) Project divided into 6 main areas: Vendor, Benefits, Provider, Claims, Medical Management and Other. Aug 24, :14 AM Aug 23, :35 PM 14 We will not have as much control over financial neutrality. Aug 22, :48 PM 15 -More dedicated staffing resources were required than initially expected. -Lack of detailed information from CMS has led to delays in business and system design and development. -Important to have Senior Leadership heavily interested in order to champion/push ahead with development. Aug 22, :10 PM 16 There is more ICD code hardcoded in applications than expected Aug 22, :00 PM 17 Business areas were not using the same reference sources for ICD codes and descriptions. 18 For dentistry brand new concept to require diagnosis codes. Policy development more challenging due to lack of coding standards and benefits structures surrounding medical systemic conditions Aug 22, :35 AM Aug 20, :22 AM 19 It takes a lot longer than initially planned for. Aug 18, :14 PM 20 alot we don't know need senior management buy-in resources are scarce consultants are expensive 21 The biggest challenge faced by the ICD-10 project continues to be managing and adapting to he ongoing project and policy changes in the agency as well as our ability to integrate those changes while continuing to meet our schedule. Central to this risk are the new DRG Grouper project that will be implemented Aug 17, :26 PM Aug 16, :53 PM 2 of 4

9 Page 7, Q12. What are some of the key findings/learnings you identified as part of your Impact Assessment? 10/1/2011 and the NCCI project. Each has downstream implications on ICD-10 implementation. 22 Overall effort is a significant undertaking and should not be underestimated. Getting an early start is paramount to an organization's successful transition. One of the more significant challenges for payer organizations is determining impact on payment neutrality. 23 No field length changes are necessary within the MMIS to accommodate ICD10 diagnosis codes or ICD10 surgical procedure codes. The MMIS support diagnosis code lengths up to 10 characters. The use of Effective/End Dates will allow the MMIS to control the use of ICD9 or ICD10 codes within the MMIS reference subsystem. For instance, the MMIS reference tables will be modified to include Effective/End Dates for all diagnosis codes and surgical procedure codes. This will allow ICD9/10 codes to be stored on the same tables, with ICD9 codes end-dated as of 09/30/2013 and ICD10 code entered with Effective Dates starting on 10/01/ There is a lack of direction regarding design decisions common to all states such as Span Billing and EPSDT groups. 25 Importance of identifying a DRG grouper that will support ICD-10 Importance of having a program person lead the project instead of treating it stricly as an IT initiative 26 Significant amount of training required Heavily impacted across people, process and technology Training most likely required before and after implementation 27 There are a lot of non-technical impacts and some departments are still looking at this as a 'systems' issue. 28 GEMs have significant errors in mapping. Some items for change are internal only and therefore do not need to be completed until closer or even after the implementation date. Nearly every area of the company is impacted in some way by ICD It will be a challenge to sequence the upgrades of various third-party applications to allow adequate testing. Code translation from ICD-9 to ICD-10 is just the beginning. We have to get ICD-10 codes down to the HCC level. 30 More impacted areas than anticipated causing more implementation issues in coordinating this at the enterprise level. Found areas where there were knowledge gaps that needed to be filled to determine the business and technical solutions Aug 16, :15 PM Aug 15, :54 PM Aug 15, :51 AM Aug 14, :31 PM Aug 11, :19 PM Aug 11, :54 PM Aug 10, :13 AM Aug 10, :26 AM Aug 10, :20 AM 31 Modeling of provider reimbursement is required. Aug 9, :01 AM 32 In our assessment each of the subsystems in the MMIS we identified for online and batch enviroments that impact the ICD-10 requirement have on each of the subsystems. We have learned that it will take many internal deliberations and discussions with our vendor in order define the framework to develop our detailed solutions. 33 Business SMEs need more training to be able to understand the impact to their business processes. Still viewing this as primarily an IT change. Hoping to arrange some additional training in-house. Aug 9, :21 AM Aug 8, :49 PM 3 of 4

10 Page 7, Q12. What are some of the key findings/learnings you identified as part of your Impact Assessment? 34 not completed Aug 8, :13 PM 35 Remember to pick up on the smallest of details: reports impacted by diag codes, small applications developed within business sites but outside of IT Department ownership, etc. Aug 8, :17 PM 4 of 4