Whether the compliance deadline delay announced last February by the Department of Health and Human Services stalled progress on ICD-10, or provided an opportunity to hone implementation timelines, all depends on where a particular healthcare organization was prior to that announcement.
"Different people got different things out of the delay. Those who were under way just used the time to rethink some remediation approaches and do some extra planning," said Steve Sisko an analyst and technology consultant focused on ICD-10. "Some payers and vendors used the time to plan for deriving more strategic remediation approaches or retire some applications and business processes that they might have otherwise just remediated."
It seems that other health entities - mostly the small clearinghouse, payers, providers and some vendors that were not far along prior to the delay - did not reap benefits out of the extra 12 months.
"The group of providers and payers that I am concerned about are the small-to-mid-size. The majority of the 5,000 hospitals in the U.S. do not have the resources to hire professional services firms so despite their desire to be compliant, they will be challenged to meet the deadline," said Fletcher Lance, national healthcare leader and vice president of Atlanta-based North Highland consultancy. "Many of these hospitals have razor thin margins today, so any disruption in the revenue cycle for them could be fatal."
Among the unchanged aspects: ICD-10 is only one of the ingredients in the healthcare CIO's kitchen. Meaningful use, quality metrics, the potential for cash flow disruption, new HIPAA privacy and security regulations, and the list goes on.
What's more, physician practices must rely on external trading partners to comply with ICD-10, said Robert Tennant, senior policy advisor at the Medical Group Management Association (MGMA), including billing companies, clearinghouse, outside coders, payers and practice management software vendors.
"While additional time for these types of industry transitions is always welcome, ICD-10 poses challenges that we have never seen before for these types of HIT mandates. If even one of the trading partners is not ready by Oct. 1, 2014, practices may experience cash flow disruption," Tennant said, adding that the industry has yet to see a flurry of plans or vendors trumpeting their readiness to test with providers. "There is the additional issue that physician practices for the most part do not want this new code set and believe that there will be little to no return on investment. Practices have few human or financial resources to divert toward ICD-10."
Larger providers are ahead of the smaller practices, engaging readiness assessments and, in some cases, even remediating gaps, North Highland's Lance said. "The proof will be in the pudding," Lance added, "as payers and providers start the end-to-end testing process to see how well their efforts have worked." n
