Executive Guide For Mitigating ICD-10 Risks

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1 Executive Guide For Mitigating ICD-10 Risks TELNET 2750 April 19, 2012 / 1-2 PM EDT

2 The Kiran Consortium Group LLC EXPERIENCE DELIVERY EXCELLENCE INTEGRITY Agenda Introduction: Mitigating ICD-10 Risks Risk Mitigation Approaches Conclusion Questions Bibliography Contact Information Notice: Reproduction, in full or in part, of this presentation is expressly prohibited without express written consent of The Kiran Consortium Group, LLC. 2

3 INTRODUCTION: Train HIPAA 5010 Remediation HIPAA Security Plan Assess HIPAA Privacy Educate Governance Contingency Planning System Upgrades Test ICD-10 MITIGATING ICD-10 RISKS 3

4 Introduction: Mitigating ICD-10 Risks We are told we are about to witness a perfect storm of various, U.S. healthcare initiatives. While this may be the case, we believe that each organization has the ability to address ICD-10 through consistent, careful, and continuous planning. An enterprise-wide, crossfunctional initiative requires both a strategic and tactical focus. Within this effort, know your risks and manage them. 4

5 Introduction: Mitigating ICD-10 Risks Mitigating potential risks related to the transition from ICD-9 to ICD-10 remains a formidable task for any healthcare organization. Begin efforts early to plan for the transition including the development of mitigation strategies to safeguard any potential deleterious effects throughout and across your organization. 5

6 Introduction: Mitigating ICD-10 Risks Where are we today? 6

7 Introduction: Mitigating ICD-10 Risks ICD-10 compliance is NOT a single functional or department effort or the responsibility of a few. ICD-10 compliance IS an enterprise-wide effort that requires Executive oversight and continuous support to mitigate potential risks. 7

8 Introduction: Mitigating ICD-10 Risks What is the actual scope of impact of ICD-10? Conceptual Model 8

9 Introduction: Mitigating ICD-10 Risks Sample: Comprehensive, Compliance Timeline with Key Initiatives 9

10 Introduction: Mitigating ICD-10 Risks Where does an Executive begin? Ten approaches for mitigating potential, ICD-10 risks: Cash Acceleration / Cash Release Plan, Plan and Plan Again Escalation Procedures Contract Review Learning Curves Technology: How much is required? Lessons from the World Information Management Contingency Planning / Contingency Funding Communication 10

11 RISK MITIGATION APPROACHES 11

12 1. Cash Acceleration / Cash Release To date, the anticipated financial impact of achieving ICD-10 compliance appears to be a subject of debate depending on the source of the information. An Advisory Board analysis projected that net revenue of a typical 250-bed hospital will decline by $1 million to $2.5 million in 2014 because of erroneous coding, payment errors and denials, and inadequate mapping to DRGs in contracts. The analysis puts the three-year impact at a loss of $2.5 million to $7.1 million in net revenue. Hospitals & Health Networks, September 2011 Note: Various investment estimates are found in the March 22, 2012 presentation. The next presentation, Developing an ICD-10 Budget, on May 10, 2012 will provide more information about how to draft a realistic compliance budge, Source: Morrissey, John. Your ICD-10 To-Do List, Hospitals & Health Networks, September, 2011, pp

13 1. Cash Acceleration / Cash Release Given the potential financial impact to every and any healthcare organization, the first mitigation approach is to focus on.. Cash Acceleration / Cash Release. What does this mean for us? Review all areas of Revenue Cycle Identify where improvements can be applied Determine whether improvements are derived from workflow, policies, procedures, Information Technology (IT), and/or selective, sourced options Monitor to metrics / Compare with industry benchmarks 13

14 1. Cash Acceleration / Cash Release What are the potential risks that this effort can mitigate? Claims Rejections / Claims Denials (e.g. due to technical issues or inappropriate ICD-10 coding) Potential Case Flow Delays Unexpected Changes in Payment Payer Contract Market Share Changes Due to Costs Flawed, Organizational Decision-Making Based on Information Shifts Regarding Service Lines, Reimbursement Versus Cost 14

15 1. Cash Acceleration / Cash Release Compliance is a Team Sport Even if your organization takes preventative measures to minimize risk related to Finances, any Business Partner can impact your efforts. Your Business Partners and You Clearinghouses Payers Information Technology Vendors Sourcing Vendors 15

16 1. Cash Acceleration / Cash Release Managing Revenue Risk As part of a holistic risk mitigation strategy, providers must understand and be able to forecast possible changes to cash flow and engage in advanced planning to protect revenue losses before, during, and post ICD-10 conversion. Healthcare providers must aggressively take advantage of the time remaining to diagnose and put in place a risk mitigation plan that will address any fluctuations from moving to ICD-10. As providers make this transition, they must consider several points in any review. Source: Mahan, Beth. ICD-10 revenue neutrality: 9 ways to protect your cash flow, Healthcare Payer News, November 14,

17 1. Cash Acceleration / Cash Release How to Achieve Revenue Neutrality 1. Discuss budgeting avenues for additional cash reserves if material delays in payment occur 2. Conduct financial modeling to understand financial implications moving from ICD-9 to ICD-10 and determining the revenue impact by provider or system facility, service line and geography 3. Review managed care contracts to negotiate protective language relevant to reimbursement in the event payment shifts occur that could have a negative impact on your bottom line 4. Engage with your high-volume payers to assess their readiness state to process your claims coded in ICD Conduct clinical documentation improvement reviews using ICD-10 code set Source: Mahan, Beth. ICD-10 revenue neutrality: 9 ways to protect your cash flow, Healthcare Payer News, November 14,

18 1. Cash Acceleration / Cash Release How to Achieve Revenue Neutrality (continued) 6. Develop a strategy for coding, billing and claim backlogs to improve cash flow 7. Determine strategy for denials management pre- and post-icd-10 conversion 8. Assess readiness state of external vendors who support coding, billing, follow up and denials 9. Review audits occurring that may be impacted by compliant use of ICD-10 over time These 9 considerations represent tactical efforts to work toward achieving revenue neutrality for your healthcare organization. Source: Mahan, Beth. ICD-10 revenue neutrality: 9 ways to protect your cash flow, Healthcare Payer News, November 14,

19 1. Cash Acceleration / Cash Release What is the anticipated amount of revenue impact? Survey conducted by HealthLeaders in July, 2011: 19

20 1. Cash Acceleration / Cash Release How long will revenue be impacted based on ICD-10 implementation? Survey conducted by HealthLeaders in July, 2011: 20

21 1. Cash Acceleration / Cash Release What reasons might contribute to projected decreased ICD-10 revenues? Survey conducted by HealthLeaders in July, 2011: Key to Types of Reasons: A Incomplete Physician Documentation B Payers will not be ready in time C Coding staff mistakes D Shift in DRGs E Delay in submission of bills F Our technology will not be ready in time G Not sure 21

22 2. Plan, Plan and Plan Again Planning is not a static exercise. Given the many functional areas and constituencies that will be impacted over the course of the ICD-10 compliance efforts, Planning will be an iterative process. Why? Multiple, internal areas of impact Multiple, external Business Partners Some information will not be immediately available either from internal sources or external sources 22

23 2. Plan, Plan and Plan Again Who will participate in the Planning effort? The Steering Committee that functions as the Governing Body for this enterprise-wide initiative. Tips for Planning Effort(s): Revisit the Plan routinely Update Plan as new information is made available and creates an impact on previously identified tasks / activities Ensure that each potential Risk is documented and specific tasks /activities are added to the Plan to manage, diminish and/or eliminate each Risk Inform Executives and Board of Director of substantive changes to the Plan and management of Risk(s) within the Plan 23

24 3. Escalation Procedures One important approach to mitigate potential risks on such an expansive program like ICD-10 compliance is establishment of an Escalation Procedure. Why? To ensure timely communication of challenges or concerns that a Work Group or other program participants cannot readily resolve To highlight a new or consequential risk that will negatively impact one or more compliance tasks 24

25 3. Escalation Procedures Value of Escalation Procedures Why? (continued) To secure decision-making by a core, Executive team, that can understand decision ramifications across disciplines, departments and the enterprise To prevent any undesired or unintended consequences from program participants that use their initiative to make required decisions To circumvent politics or personalities that are uncomfortable with prescribed ICD-10 compliance tasks and activities 25

26 4. Contract Review All contracts for Trading Partners / Vendors as well as Payers / Clearinghouses should be reviewed as part of a Communication Plan and documenting status of Compliance efforts with timeline. From an IT Perspective: Identify main contact for on-going communication about progress on ICD-10 Secure timeline as to when Vendors (IT and Sourced Services) will be releasing upgrades that are ICD-10 compliant Add anticipated effort, resources, and timelines for required implementation (Testing / Validation) Develop Contingency Plan(s) 26

27 4. Contract Review Health Plan Contract Review: Identify contract renewal dates Confirm whether current ICD-9 codes will be converted to ICD-10 Determine whether existing contracts will be converted to ICD-10 Validate method Health Plan will use to convert to corresponding ICD-10 codes Understand how Health Plans will approach reimbursement / Determine whether there are changes that require re-negotiation of contract Determine accuracy of reimbursement mapping from Health Plan Undertake proactive approach in ICD-10 mapping to better engage in provider/payer contracting efforts Confirm timelines: conversion, testing and validation (internal efforts required) Source: American Hospital Association. HIPAA Code Set Rule: ICD-10 Implementation, An Executive Briefing ; pp ncvhs.hhs.gov/091210p06b.pdf 27

28 14,000 Diagnosis Codes 4,000 Procedure Codes ICD-9 5. Learning Curves A Snapshot of Things to Come ICD-10 Requires Documentation Granularity 68,000 Diagnosis Codes 87,000 Procedure Codes ICD-10 Angioplasty (procedure code) 1 code Angioplasty (procedure code) 854 different codes 047K047 Specify body part, approach, and device Pressure Ulcer (diagnosis codes) 7 codes Show location but not depth No Equivalent ICD-9 Code Indicated through notes and other methods Pressure Ulcer (diagnosis codes) 125 different codes L Show specific location, depth, severity, occurrence Y71.3 Surgical Instruments, materials, cardiovascular devices associated with adverse incidents Source: Adapted from United Healthcare sicd10 Transition Playbook, May 25,

29 5. Learning Curves Given the magnitude of codes as compared to ICD-9, it is clear that a natural learning curve will exist for Coders and Physicians alike. Coding under ICD-10 requires a new level of knowledge for the coding professional, not only to support the basics of coding but also to become more engaged in an understanding of the patient s condition, the nature of procedure, and the pathophysiology and anatomy that relates to these conditions and procedures. Source: ICD-10: A New Dynamic in the Relationship Between Clinicians and Coders, 2012, AAPC. Joe C. Nichols, M.D., Principal, Health Data Consulting and Rhonda Buckholtz, CPC, CPMA, CPC-I, CGSC, COBGC, CPEDC, CENTC, Vice President - ICD-10 Education and Training at AAPC 29

30 5. Learning Curves Who will face ICD-10 learning curves? Coders Risk Managers Physicians Researchers Case Managers Executives Anyone who views reports based on ICD-10 data 30

31 5. Learning Curves What approach might we take to support the learning curves of healthcare professionals? Preparation: Update Current ICD-9 Skills Preparation: ICD-10 Classes Note: Graphic based on previous, ICD-10 compliance deadlines Transition Preparation: Dual Coding Go-Live Support Remediation Assistance/Training

32 5. Learning Curves Who will face ICD-10 learning curves? Physicians! The heart of ICD-10 is found in the need to improve Physician Clinical Documentation today in preparation for tomorrow. In the ICD-10 Plan confirm that there are training and education resources specific to Physicians A variety of training methods may be required to best support Physician learning preferences (e.g. virtual, face-to-face, structured classroom learning, peer-based training, etc.) Work with Physician executives to develop requirements and advance communication about this effort 32

33 5. Learning Curves What sources can assist with ICD-10 education and training? Professional Societies (e.g.. ACHE, AHA state level chapters, HFMA, AHIMA, AAPC, MGMA, AMA (Amer. Medical Association),CHIME, HIMSS, etc.) Internal Staff (e.g.. Chief Financial Officer, Health Information Manager, Revenue Cycle Manager, Chief Information Officer, etc.) Certified Staff (e.g.. ICD-10 Certified Trainer) ICD-10 Webinars and Workshops (e.g.. sponsored by various professional societies and industry firms) White Papers / Reports / Articles External Firms and Vendors 33

34 6. Technology: How Much Is Required? How will I know? Information Technology (IT) is a key tool to most healthcare organizations. Assessment of current IT environment / Requirement identified Inability of a vendor/business partner to update/upgrade their current software to be ICD-10 compliant Potential Scenarios: Upgrade existing IT (e.g. software, hardware, testing, implementation, etc.) Replace existing IT Acquire and implement new IT to support compliance 34

35 6. Technology: How Much Is Required? Current IT Landscape Proliferation of New Tools. Technologies and Applications in Support of ICD-10 Compliance: Data Modelling Crosswalks Simulator Tools Testing Tools Self-Assessment and Project Planning Tools No single product can provide 100 % accuracy for translation of ICD- 9 to ICD-10 codes via Crosswalks and/or Data Modelling. 35

36 7. Lessons From the World Many times we look to those who have paved the way before us to learn and apply these lessons toward our future success. Australia RAND Corporation Technical Report (2004): Australia s experience is similar [to that of Canada], although the change Australian coders went through was fairly modest: from 12,500 to 14,000 disease codes and from 3,600 to 6,000 procedural codes. As with Canada, introduction was staged Source: Rand Corporation. The Costs and Benefits of Moving to the ICD-10 Code Sets, March, 2004, Martin Libicki and Irene Brahmakulam, TR-132-DHHS.; page 16. Prepared for the Department of Health and Human Services. 36

37 7. Lessons From the World Canada Canada only uses ICD-10 for statistical purposes, not for billing Reports to date, both retrospective and prospective, suggest that for a medium to large acute-care facility, an initial productivity decrease in the neighborhood of 50 percent is to be expected According to reports published by the American Health Information Management Association (AHIMA) and the American Hospital Association (AHA), at one 605-bed hospital in Canada, a conversion to ICD-10 indicated that after one year, coders had recovered some of their pre-conversion productivity rates (see for the full report). Source: Hallowell, Bruce.. What Canada Can Teach the U.S. About ICD-10 Conversion, HealthcareIT News, September 14,

38 7. Lessons From the World Canada The Canadian experience was that coders became sufficiently proficient with the new codes well inside six months, with no reported loss in long term productivity. As such, estimates that each U.S. coder would need a week s worth of training are not inconsistent with Canada s experience of three days plus extras. [1] For inpatient records, one month post conversion, coders were coding generally at rates just under 50 percent. One year later, they had returned to 81 percent of their former 4.6 charts hourly, and for day surgery and emergency records, 79 percent and 85 percent, respectively. [2] Source: [1] Rand Corporation. The Costs and Benefits of Moving to the ICD-10 Code Sets, March, 2004, Martin Libicki and Irene Brahmakulam, TR-132-DHHS.; page 16. Prepared for the Department of Health and Human Services. Source: [2] Hallowell, Bruce.. What Canada Can Teach the U.S. About ICD-10 Conversion, HealthcareIT News, September 14, , page

39 7. Lessons From Canada Canadian Duration of Effort: 2001 through 2006 Source: Canadian Institute for Health Information. Understanding ICD-10-CA and CCI for Analysis and Trending, September 21, 2008, p. 18, Linda Tourney- Lewis, BHA, MHS, CHIM. 39

40 7. Lessons From the World WHO Released 14,400 ICD-10 Diagnoses Codes Canadian experts added about 4,000 more codes to the ICD-10-CA and address beyond the Acute Care setting CCI = Canadian Classification of Interventions [Comparable to ICD-10-PCS] Source: Canadian Institute for Health Information. Understanding ICD-10-CA and CCI for Analysis and Trending, September 21, 2008, p. 18, Linda Tourney- Lewis, BHA, MHS, CHIM. 40

41 8. Information Management While much of the focus for ICD-10 is on the processes and technology, little attention is spent addressing the data that a healthcare organization used to make vital business and clinical decisions. Data is a corporate asset that guides the enterprise and supports critical decision-making. Reports need to be identified since time, effort and resources need to be assigned to manage and interpret the changes in data. Board Reports, Executives including Physicians and Clinicians, Service Line Managers, External Agencies, Payers, etc. 41

42 Data Impact of ICD-10 Compliance 8. Information Management Source: Source: Slide adapted by The Stellar Group Consultants from an original slide created by Dwan Thomas-Flowers, MBA, RHIA, CCS, Mayo Clinic, Jacksonville, FL Presentation: ICD- 42

43 8. Information Management What do we do? Inventory all reports from direct data Inventory all reports generated by data for secondary uses Identify all business owners for these reports Ensure that the Plan for ICD-10 includes efforts specific to Information Management Determine how reports will be managed during the transition period Examples of specific areas of effort [1]: Revenue cycle reporting and analysis will need to be redesigned in areas that rely on ICD-9 codes for reporting today Case mix adjustment will be substantially different under ICD-10 because of the changes in the definition of severity, comorbidities, complications, and other parameters of measures of the disease burden Source:: [1] The Advisory Board Company. ICD-10 Hospital Impacts (Applications and Technologies Collaborative Research Report), May 20, Joe C. Nichols, M.D. 43

44 9. Contingency Planning/Funding We can hope to achieve our CID-10 compliance goal, but managing and mitigating risk is best served by Contingency Planning and Funding. What if our payer(s) is not compliant one or more of our IT vendors is not compliant we fall behind with our ICD-10 efforts we experience significant cost overruns with ICD- 10 preparations we have a high number of claims rejected and so on. 44

45 9. Contingency Planning/Funding When your Steering Committee engages in a What if exercise, this is an important component to manage Risk. Tips: This is not a one-time effort only. Revisit Plan B on a regular basis The allocation of resources for most programs/projects resource allocation is consistently underconfigured Communicate information about the Contingency Plan to both Board members as well as ICD-10 Steering Committee Include C-Suite Executives, Legal Counsel, Chief Medical Officer, Risk Manager, and Any Other Pertinent Decision-Maker 45

46 9. Contingency Planning/Funding Tips (continued): Plan for a disruption in cash flow [Note: Predictions range wildly from various sources] Identify Cash Reserves and begin to set funds aside in the Operating Budget Additional labor costs must be factored into the proposed plan with budget since productivity will be decreased for a period of time after go-live External resources may be required to supplement current coders so as not to backlog completion of medical records and submission of claims Some additional education and remediation resources may be required for Physicians, Coders and others in the months following go-live (factor in for 6-9 months minimum) 46

47 10. Communication Communication is nothing new. Successful programs/projects are built on effective communication. What is the best approach for us? Type(s) of communication vehicles (e.g. electronic ,face-to-face, newsletter, web site, collaboration tools. road show, etc.) Frequency of communication Targeted messaging approach by constituency Designated spokesmen 47

48 10. Communication Finding the best communication approach for your healthcare organization will require feedback from the various constituencies to ensure that it is. Tips Identify previous initiatives that have been deemed successful What type of communication worked best? Tailor your Communication Plan and adjust, as required, to best fit. Ask constituents what information would be most helpful. Balance communications based on other concurrent initiatives (e.g. information overload) Timely, Relevant, In context with the targeted constituency, and Builds upon previous communication efforts. 48

49 CONCLUSION 49

50 Conclusion The challenges to achieve ICD-10 compliance are many but coordinating all its important components will support your internal and external efforts. A few final thoughts. Executive participation and engagement is essential to mitigate risks Know the capacity and capability of your organization to engage in required tasks and activities Realistic resource allocation and planning for the entire compliance cycle and beyond is essential 50

51 Conclusion A few final thoughts. Do not wait for your Business Partners to contact you / Be proactive to better identify the scope of effort required as well as budget implications Delegation is important to execute required tasks and activities to achieve compliance but every healthcare organization today is challenged by its capacity to take on more concurrent projects Inform the Board of Directors about the on-going ICD-10 compliance efforts as well as challenges / Share Contingency Plans well in advance 51

52 Conclusion A few final thoughts Labor costs are always greater than initially estimated Education and training for Physicians, clinicians, HIM professionals and all others using ICD-10 data and information is not a one time expense 52

53 Conclusion What do you anticipate as the greatest challenge or concern in meeting ICD-10 compliance? Survey conducted by HealthLeaders in July, 2011: Key to Challenge or Concern: A Physician cooperation B Staff training C Funding D Payer readiness E Vendor readiness F Meeting the deadline 53

54 Conclusion A recognized leader in change management research pointed to the ability of an organization to efficiently and effectively manage the changes a project brings about in the organization. Survey conducted by ProSci in 2003: Projects: Greatest Success Factors Effective and strong executive sponsorship Buy-in from front line managers and employees Exceptional teams Continuous and targeted communication Planned and organized approach Projects: Greatest Obstacle Factors Employee resistance at all levels Middle-management resistance Inadequate executive sponsorship Limited time, budget, and resources Corporate inertia and politics Source: Petouhoff, PhD, Natalie, Chandler, Tamra, and Montag-Schmaltz, Beth. Wthe Business Impact of Change Management, Graziadio Business Review, 2006, Volume 9, Issue 3. [Graziadio School of Business and Management, Pepperdine University, Malibu, CA] 54

55 Questions 55

56 Bibliography White Papers A CEO s Guide to Advancing ICD-10 Efforts, May, 2011, Joseph J. DeSilva, FACHE, and Lucy Mancini Newell, MBA, FHIMSS. The Kiran Consortium Group LLC. A CEO s Guide to Mitigating Risk for ICD-10 Compliance, August, 2011, Joseph J. DeSilva, FACHE, and Lucy Mancini Newell, MBA, FHIMSS. The Kiran Consortium Group LLC. Cracking the Code: Physician Clinical Documentation and ICD-10, January, 2012, Dr. Todd Husty, FACEP, and Lucy Mancini Newell, MBA, FHIMSS. The Kiran Consortium Group LLC. ICD-10: Data Impact Across the Enterprise., April, 2011, Willie Williams III, PMP, and Lucy Mancini Newell, MBA, FHIMSS. The Kiran Consortium Group LLC. Available at the Healthcare Information Management and Systems Society (HIMSS) web site: ICD-10 Implementation for Health Care Providers: The business imperative for compliance, August, 2010, Deloitte. 56

57 Bibliography White Papers (continued) ICD-10: A New Dynamic in the Relationship Between Clinicians and Coders, 2012, AAPC. Joe C. Nichols, M.D., Principal, Health Data Consulting and Rhonda Buckholtz, CPC, CPMA, CPC-I, CGSC, COBGC, CPEDC, CENTC, Vice President - ICD-10 Education and Training at AAPC Presentations Canadian Institute for Health Information. Understanding ICD-10-CA and CCI for Analysis and Trending, September 21, 2008, Linda Tourney-Lewis, BHA, MHS, CHIM. Reports Canadian Institute of Health Information. The Canadian Enhancement of ICD-10, FINAL REPORT, June, cd10 HealthLeaders. Intelligence Report - ICD-10 Puts Revenue at Risk, July, Karen Minich-Pourshadi.. The Advisory Board Company. ICD-10 Hospital Impacts (Applications and Technologies Collaborative Research Report, May 20, Joe C. Nichols, M.D. Executive Briefing American Hospital Association. HIPAA Code Set Rule: ICD-10 Implementation, An Executive Briefing

58 Bibliography Articles Cheung, Karen M.. ICD-10 switch could cost hospitals up to $20M, FierceHealthcare, June 14, Hagland, Mark. An HIM Association Perspective on the ICD-10 Transition; An AHIMA executive scans the field, Healthcare Informatics, November 21, F18BE895F87F791&tier=4&id=CBC9812A5B E897DE0E88CF&WA_MAILINGLEVEL_CODE= Halamka, MD, John. The Challenge with ICD-10 Implementation,, HealthcareIT News, September 22, Hallowell, Bruce.. What Canada Can Teach the U.S. About ICD-10 Conversion, HealthcareIT News, September 14, Mahan, Beth. ICD-10 revenue neutrality: 9 ways to protect your cash flow, Healthcare Payer News, November 14, revenue-neutrality-9-ways-protect-your-cash-flow 58

59 Bibliography Articles Mearsian, Lucas. New medical coding system taxes hospital IT resources, ComputerWorld, June 13, d=11 Morrissey, John. Your ICD-10 To-Do List, Hospitals & Health Networks, September, 2011, pp Petouhoff, PhD, Natalie, Chandler, Tamra, and Montag-Schmaltz, Beth. Wthe Business Impact of Change Management, Graziadio Business Review, 2006, Volume 9, Issue 3. [Graziadio School of Business and Management, Pepperdine University, Malibu, CA] Rodak, Sabrina. What You Should be Doing to Prepare for ICD-10: 3 Strategies, Becker s Hospital Review, May 10, /what-you-should-be-doing-to-prepare-for-icd strategies.html Professional Society Canadian Institute of Health Information. ion/standards/classification+and+coding/codingclass_icd10 59

60 Contact Information Lucy Mancini Newell, MBA, FHIMSS Managing Partner Cell Phone: Addresses: Corporate Phone Number: Web Site: Visit our web site for presentations, blogs, and white papers. 60

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