HIPAA-compliant electronic transactions under 5010 and ICD-10 represent a sweeping change to the healthcare industry, affecting alerts, information systems, processes, rules, operations, and staff. Among providers of care, hospitals are affected the most, as they are required to implement ICD-10-CM with approximately 68,000 codes and ICD-10-PCS with approximately 87,000 codes. Physician practices are required to implement ICD-10-CM only and may continue to use CPT-4 for procedures.
The change from ICD-9 to ICD-10, with the substantial increase in the number and specificity of codes, will require practices to reengineer the documentation of encounters. In order for a hospital to advance its hospital-physician network toward compliance, it needs to focus on the interoperability of data, usage of an EMR with Common Medical Terminology across the network, and ensure a comprehensive approach to revenue cycle management.
A major part of the Federal government's push to implement EMR is to achieve the interoperability of care data, which means that patient data can be shared among providers of care, promoting more choice of providers by consumers and eliminating or reducing duplicate diagnostic testing.
However, the sharing of such data among EMRs in any meaningful way will not occur soon. The reality is that data is normally not shareable other than in summary form, such as a computer file or printout, even among EMRs from the same vendor. This lack of interoperability is primarily because of a lack of an information architecture with a Common Medical Terminology (CMT), such as the standardized use of SNOMED CT for documentation input mapping to ICD-10 output.
There are actually two transitions in moving to ICD-10. One is implementing the ICD-10 code sets, and the other is figuring out how to use both ICD-9 and ICD-10 for a minimum of two years. Effectively transitioning to ICD-10 will require hospital-physician networks to implement EMRs, but adjusting to an EMR is not without its difficulties:
All of this obviously impacts a practice's business partners, including the hospital.
Rather than taking a piecemeal approach to ICD-10 compliance, our methodology uses a comprehensive Change Leadership/Business and Clinical Process Reengineering approach to Revenue Cycle Management. Not reengineering the revenue cycle exposes practices to significant financial risk, which in turn increases risk for hospitals. TM Floyd & Company can assist practices in the review and modification of the entire process from documentation through coding, claim submission, billing, and collection.
Remember: Unlike the HIPAA Privacy and Security Rules where providers often chose how and at what level they were going to comply, thereby risking fines that might have been less than the cost of compliance, for the Electronic Transactions and Code Sets Rule, there is no compliance middle ground. In the short-term, the Rule requires compliance to receive payment from Medicare, Medicaid, and all third-party payers. In the long-term, it is required for pay-for-performance (P4P).