AMARILLO, TX – For several years now, the health care industry has been told that the transition from the 9th to the 10th revision of the International Classification of Diseases, Clinical Modification (ICD-10-CM) is imminent, only to have the can kicked down the road a little farther each time.  This time around, however, it appears that the October 1, 2015 transition (only 171 days from today) is going to happen.  Are you ready?

Although ICD-10 is new to the United States, it has been used in other countries since 1994.  In fact, ICD-10 is currently under revision.  The release of ICD-11 is anticipated in 2017, but do not expect that implementation of ICD-10 will be deferred until the 11th revision is published.  If you have not already begun preparing for the transition, now is the time to start.

ICD-10 consists of two parts: ICD-10-CM and ICD-10-PCS.  ICD-10-CM is the diagnosis classification system developed by the Centers for Disease Control and Prevention for use in all United States health care treatment settings.  ICD-10-CM uses from 3 to 7 alpha and numeric digits and full code titles in a format that is similar to ICD-9-CM.  ICD-10-PCS is the Procedure Classification System developed by CMS for use in the United States for inpatient settings only.  This new Procedure Coding System uses 7 alpha or numeric digits, making it much more specific than ICD-9-CM, which uses only 3 or 4 numeric digits.

For example, ICD-9-CM lists 9 location codes for a pressure ulcer.  The ICD-9-CM codes reflect the general location of the pressure ulcer but not its depth.  In comparison, ICD-10-CM lists 150 pressure ulcer codes, which more specifically reflect the ulcer’s specific location and depth.

Together, ICD-10-CM and ICD-10-PCS include 155,000 codes, a vast increase over the 18,000 codes in ICD-9-CM.  The additional codes allow greater specificity, which is expected to provide more meaningful data and help facilitate improvements in areas such as quality reporting, documentation reduction, and detection of health care fraud and abuse, to name a few.

What do you need to do to get ready?  First, assess the impact ICD-10 will have on your organization.  For example, how will the transition affect the people in your organization who use ICD-coded data?  How will this affect the business processes that revolve around the use of ICD-coded data? How will this affect the systems that involve ICD-coded data?

Next, plan out the activities your organization needs to complete and determine the resources needed.  For example, what training does your staff need? What changes to business processes are needed?  Identify all of the existing ICD-9-CM touch points for your system and determine how those touch points will need to change.

Then, implement your plan, including end-to-end testing (or “dry runs”).  As you modify your policies and processes, perform follow-up assessments to identify additional required modifications and decrease second and third order ripple effects that may otherwise be unanticipated.  Document and share your “lessons learned” with others to help take the sting out of the process.  Additionally, plan on longer processing times for your organization and outside organizations (including CMS) during the transition period so you are not caught off guard by a longer reimbursement cycle.  Do not let October 1, 2015 arrive and catch you unprepared.             

Jeffrey S. Baird, JD, is chairman of the Health Care Group at Brown & Fortunato P C, a law firm based in Amarillo, Tex. Jill S. Vogel, JD, is an attorney with the Health Care Group at Brown & Fortunato PC. They represent pharmacies, HME companies, and other health care providers throughout the United States. Baird and Vogel are Board Certified in Health Law by the Texas Board of Legal Specialization. Baird can be reached at (806) 345-6320 or [email protected]. Jill Vogel can be reached at (806) 345-6343 or [email protected]