Industry Watch

Dawn Duchek	Shelly Guffey

On April 9, the Department of Health and Human Services (HHS) announced a proposed rule to delay the ICD-10 compliance date from Oct. 1, 2013, to Oct. 1, 2014. Some providers experienced “implementation issues” while transitioning to 5010, and they fear the 2013 deadline won’t allow enough time to fully implement ICD-10. Now that an extension has been proposed, many practices wonder if they should delay their transition or continue as planned.

Regardless of the possible deadline delay, we recommend continuing to move forward on your ICD-10 preparation. As the industry learned from recent 5010 transition challenges, it’s never too early to prepare! Here are seven ways that you can make the most of any extra time the delay provides.

1. Conduct more thorough in-office analysis to identify each of the day-to-day processes and areas of your practice that will be impacted. For example, both your clinical documentation and your office superbill will need to be converted to include ICD-10 codes.
2. Ensure that you have a strong plan in place to train your billing and clinical staff in ICD-10 coding changes. At a recent AAPC Boot Camp on ICD-10, it took participants four hours to code 20 cases – and that’s with the help of a teacher. Having the right type of training will help cut down this time.
3. Conduct time studies where you identify how much extra time coding will take with ICD-10. The American Health Information Management Association estimates that, initially, it will take roughly twice as long for a coder to code under ICD-10. Medical practices should expect a permanent 10 to 25 percent loss of coding productivity. What is your plan to keep up with your increased coding needs, and how will it impact you financially? Will you pay overtime, hire another coder or outsource some of the work?
4. Check with your business partners, vendors and software applications to see how they plan to handle the transition.
5. To maintain compliance requirements, medical office policies and written procedures will need to be updated to reflect ICD-10 changes. The Office of Inspector General has developed some guidelines to help practices develop internal controls and processes that may assist your office with these changes.
6. Review your payer contracts, which may be based on older codes, and work with payers to update these for ICD-10. Don’t assume payers will do it for you.
7. Establish a line of credit. The industry encouraged providers to do this with the 5010 transition, but many didn’t take this step and were caught off guard by the revenue impact of 5010. The ICD-10 switch will impact your cash flow, and most lines of credit need to be in place for six months to a full year before funds become available. Get one set up now.

In light of the proposed delay, it may be tempting to take a break from ICD-10, but the items we mention here take a long time to complete. We urge you to continue moving forward on your preparations. Doing as much as possible to prepare your practice for ICD-10 now will save you headaches as the deadline nears and will ensure that your practice continues to operate efficiently throughout the transition.

For a compilation of helpful industry resources on ICD-10, visit www.gatewayedi.com/icd10.

About the authors

Shelly Guffey is manager of premier accounts and vendor partners and Dawn Duchek is industry initiatives coordinator for Gateway EDI. For more information on Gateway EDI, click here.

HIE guide is HIMSS Book of the Year

“The Health Information Exchange Formation Guide,” co-authored by well-known health information consultants Laura Kolkman, RN, MS, FHIMSS, and Bob Brown of Mosaica Partners, was named the HIMSS Book of the Year in February. Published by HIMSS in 2011, this title provides the knowledge and tools that emerging state-, regional- or community-based HIE initiatives need to develop a framework for long-term sustainability.

This practical guide is available for purchase in the HIMSS online store and as a HIMSS e-book. For more information, including the table of contents and chapter summaries, helpful downloadable figures and checklists, visit www.himss.org/hieformationguide.

 

 

 

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National eHealth Collaborative (NeHC) recently released “Health Information Exchange Roadmap: The Landscape and a Path Forward,” a no-cost, downloadable resource that offers stakeholders a clear picture of efforts being undertaken by both the public and private sectors to create and implement the building blocks for widespread deployment of interoperable health information exchanges (HIE).

More than 75 experts and industry leaders contributed their insight and experience to make this valuable title happen. In it, they provide an understanding of how these diverse approaches fit together into a cohesive strategy for nationwide HIE.

The HIE roadmap also includes multiple examples of leading HIE-enabling organizations that are leveraging nationally recognized HIE standards to improve patient care, achieve efficiencies and realize cost savings.

Major topics covered in detail include:

1. Office of the National Coordinator (ONC)-led efforts to develop nationally recognized standards that can be leveraged by local HIE initiatives and how those standards work in harmony with local efforts to create a cohesive strategy for market-driven interoperability;
2. Examples of where national standards are currently being leveraged by diverse market-based initiatives to provide innovative HIE functionality and services; and
3. A four-phase roadmap of the major steps communities can follow to accelerate progress toward the realization of a widespread and successful deployment of interoperable EHRs, connected health IT tools and real-time information sharing through HIE.

Download this publication at www.nationalehealth.org/hie-roadmap.

 

On Feb. 23, 2012, CMS released the notice of proposed rule making (NPRM) for Stage 2 of the EHR Incentive Program, which advances the next set of criteria that eligible hospitals (EHs) and eligible providers (EPs) must demonstrate to continue to successfully achieve meaningful use.

While proposals for the next phase of core and menu set requirements largely mirror the direction the Health IT Policy Committee’s recommendations made during the summer of 2011, they are on the whole more aggressive. This is unsurprising given that everything that is ultimately included in the final rule on Stage 2 – due out summer 2012 – must be vetted in the proposed rule.

Here are 10 of the most important takeaways contained in the proposal:

1. Centers for Medicare & Medicaid Services (CMS) affirms a delay for 2011 attesters. As expected, CMS has proposed that 2011 attesters will transition to Stage 2 in 2014 instead of 2013, as initially required. All other providers will remain on schedule.
2. Stage 1 requirements will be updated come 2013. Not only has CMS proposed new measures for Stage 2, but it has also proposed an update to Stage 1 measures that better align them with the program’s strategic direction. Providers attesting to Stage 1 come 2013 will have the option to report on these new criteria. Starting in 2014, these new Stage 1 criteria will become mandatory.
3. Medicaid definitions are loosened; more providers are eligible. CMS has issued definitional modifications to patient encounters and children’s hospitals in addition to clarifications on volume determination for multi-physician practices. These act to expand the pool of providers eligible for the Medicaid program, expanding the number of EPs and EHs eligible for Medicaid incentives.
4. While the total number of objectives does not grow, Stage 2 measure complexity increases significantly. While a number of Stage 1 measures no longer exist as independent measures, these concepts are subsumed without exception into new requirements. Stage 2 measures are, on the whole, more involved than Stage 1 measures. For example, it is not uncommon for a measure to have multiple parts.
5. Information exchange will be key, but a health information exchange (HIE) will not be necessary. CMS has embedded information exchange into a number of measures, the most significant of which is the requirement that 10 percent of summary of care records be transmitted electronically. Use of Direct – essentially secure email – will be sufficient.
6. Patients will need to act for providers to succeed. The concept of a patient request is eliminated in Stage 2; instead, providers will need to proactively offer patients their health information. Further, patients will need to view, download or transmit their health information at a 10 percent threshold. While CMS continues to express its intent to transition to outcomes measures, this is the first that has been proposed and is likely to be at the center of debate in public comment.
7. Sharing of health data will force real-time, high-quality data capture. While problem, medication and medication allergy lists are no longer measures unto themselves, they have been subsumed within the summary of care record and patient health information requirements. Far from diminishing them, this will force providers to move beyond measurement (i.e., at least one problem per unique patient), as patients and clinicians view this information with greater frequency and expect accuracy and completeness.
8. More quality measures; CMS’ long-term goals – electronic reporting and alignment with other reporting programs – remain intact. Both EPs and EHs will face a significant uptick in clinical quality measure (CQM) reporting requirements, with CMS proposing 12 total requirements for EPs (up from six) and 24 total requirements for EHs (up from 15). While CMS is currently unable to accept electronic reporting other than through its pilot programs, it expects to roll out electronic reporting broadly in 2014.
9. The Office of the National Coordinator’s (ONC) sister rule proposes a more flexible certification process and greater utilization of standards. While the ONC standards and certification rule will be the subject of later analysis, providers should stay aware of this sister rule, which articulates the standards providers are required to follow to achieve meaningful use. It also outlines a new methodology for maintenance of certified electronic health record (EHR) technology, which aims to give providers the leeway to possess only those certified capabilities they will actually implement and use.
10. Payment adjustments begin in 2015. Providers that successfully attested in 2011 or 2012 will need to achieve meaningful use in 2013 to avoid a payment adjustment in 2015. Providers that have yet to achieve meaningful use by 2013 must attest to meaningful use three months before the close of the 2014 payment year to avoid a 2015 penalty. Providers must continue to demonstrate increasingly complex stages of meaningful use to continue to avoid penalties.

The Advisory Board Company’s Protima Advani, Robin Raiford and Tony Panjamapirom also contributed to this piece. Learn more at www.advisory.com.

 

“Privacy: The Impact of ARRA, HITECH, and Other Policy Initiatives,” by Jill Callahan Dennis, JD, RHIA, is a great companion guide for organizations implementing the health information privacy and security provisions of the American Recovery and Reinvestment Act of 2009 (ARRA). Topics include key provisions of the legislation, operational challenges and possible implementation strategies, and an overview of some of the other privacy- and security-related policy efforts now underway. This book will be useful to a range of users – both those experienced with health information privacy issues and those just beginning to work with ARRA’s HITECH provisions.

This title is available through the AHIMA Web store: www.ahimastore.org.

Kaiser Permanente launched a mobile-optimized version of its member website on Jan. 24, enabling nearly 9 million patients to have 24/7 access to their health information on Android mobile devices. According to the company, this is one of the largest mobile health information connectivity projects in history and is a giant step forward in improving the healthcare experience for patients, no matter where they are. An iPhone app is also expected later this year. For now, users of other mobile devices can access the same set of care-support tools at no charge through the new member website, which is available through smartphone Internet browsers.

Kaiser is one of only a handful of providers offering EHR access to its members in any way, much less via mobile devices. But Kaiser’s mobile efforts go far beyond EHR access. In 2011 alone, more than 68 million lab test results were made available online. The mobile-optimized site and the new app make that information, and much more, securely and easily available to members. Members can access their appointments and pharmacy orders, and they can exchange texts with their healthcare practitioners via the message center – all while on the go.

Kaiser Permanente patients have been able to email their doctors for five years, with more than 12 million e-visits in 2011 alone. The company expects that number to increase significantly with the new app and mobile-optimized site.

The fourth edition of “Medical Imaging Consultant (MIC4),” published by HealthHelp and RadSite, is a 250-page pocket reference guide that provides critical information on 303 clinical conditions to promote ordering the appropriate medical imaging procedures. This book is designed for health professionals, but it also can be used by patients. More than 800 peer-reviewed medical journal article references are included to promote evidence-based imaging. Copies of the book are available for purchase through RadSite’s website (via the RadSite Store at www.radsitequality.com) or through Amazon.