Last week the Workgroup for Electronic Data Interchange (WEDI), sent a letter to HHS Secretary Kathlee Sebelius. The letter included a recommended ICD-10 roadmap which outlined various steps the agency should take for a smooth transition to ICD-10. In the letter, WEDI urged HHS to publicly share Medicare and Medicaid readiness for ICD-10, speed up and expand ICD-10 testing, and expand educational support for healthcare providers. Here are some excerpts from WEDI's list of recommendations:
Communicate Medicare and Medicaid readiness: There is a need for improved transparency and readiness communication from government health plans. In particular, we encourage Medicare and Medicaid to publicly disclose all ICD-10 related readiness levels and expected testing timeframes. Sharing of new edits or revised medical policies due to ICD-10 would help trading partners understand what may or may not be changing and will assist them in determining where to place emphasis during testing.
Expand Medicare and Medicaid testing and quickly disseminate results: We believe the canceling of the limited July “end-to-end” testing sent the wrong message to the industry. Rather than delay this critical form of testing until 2015, we recommend expediting and expanding this form of trading partner testing.
Target outreach to non-covered entities: Many in the industry continue to be concerned that non-covered entities such as workers’ compensation plans will not be required to adopt ICD-10 through federal law. While some states are expected to adopt or be required through state law to adopt ICD-10, those that do not will necessitate dual workflows and increased administrative burden for providers. We recommend that HHS work with the appropriate state authorities and encourage the adoption of ICD-10 by workers’ compensation and other property and casualty carriers that utilize diagnosis and procedure codes.
Encourage an effective private sector testing process: It is not practical or feasible for every provider and payer to test with each other. Rather than trying to conduct a massive end-to-end industry testing process, it would be more beneficial to establish selective testing processes that illustrate that each key function is working correctly. For example, testing a key subset of claims for provider specialties could illustrate to each specialty that those claims are being processed correctly. Results of this testing should be shared so that it would not be necessary to test with every provider of that type.
For outpatient facilities, it may prove more useful to test eligibility and prior authorization functions than to test the procedure-based payment process that has been in place for many years. Clearinghouses might be leveraged in testing, as they have direct connections to most large payers and many provide reports on key performance indicators that can be used to identify aberrations under ICD-10.
Consider conducting or supporting limited pilots: The additional year provides sufficient time to conduct limited pilots with those covered entities that are ready and willing to send and receive standard transactions using ICD-10 codes. Results from these pilots could be widely disseminated to the industry and could help both reduce the concern regarding the impact of the new code sets and identify potential challenges and their solutions. WEDI stands ready to assist HHS in identifying pilot participants and administering the pilots.
Establish clear milestones and track readiness: Without milestones it will be difficult to measure progress. The milestones must be clearly defined regarding what constitutes meeting each milestone. Leveraging existing checklists or bullet points may be useful in this regard. Metrics must be established in order to track readiness, especially in the areas of CDI vendor readiness and clearinghouse and health plan testing. WEDI stands ready to work with HHS in identifying key milestones and tracking industry readiness.
Expand communication and messaging: We recommend HHS continue to develop and publicize educational resources or other tools and to work with WEDI and others such as local or regional resources to reach a broader audience. Industry associations should review their literature and terminology to assure consistent messaging exists to the extent possible. Communications should include success stories to illustrate that ICD-10 compliance can be done and how it can be accomplished. Messaging can also illustrate the positive aspects of ICD-10, including benefits to be realized by providers.