Six months before the October 1st, 2014 deadline, by a vote of 64 to 35, the Senate has approved legislation including a provision to delay the ICD-10 implementation deadline. This was the second approval for the bill, as it passed the House of Representatives last week and is currently on The President’s desk for possible veto. [update - The President Signed the Bill into Law on April 1st] The legislation was introduced as part of the Medicaid “Doc-Fix” bill, but specifically, the provision aims to delay the switch from the US health coding standard from ICD 9 to ICD 10 for one additional year. The ICD-CM is a US medical classification list that is the basis for our health system; every disease, disorder, symptom, or external cause of morbidity can be classified and coded for reporting and insurance claiming purposes. The ICD 9 system has been in effect for over 20 years and does not allow for the documentation of data we will be able to achieve with ICD 10, including morbidity and specificity reporting.
The switch from ICD 9 to ICD 10 is a significant undertaking for anyone involved within the US healthcare system as it affects every aspect of the industry from providers, healthcare plans, vendors, down to the admins who code claims. Everyone involved has been gearing up for the big change, spending valuable resources, time, and energy that could otherwise have been spent on value-added results for patients. Hospitals have been focusing on training and adherence initiatives, vendors have been preparing new technology, and health plans have been working reimbursement processes for the new codes. The entire industry has felt the pressure to change and had reacted accordingly to the information provided by legislation and regulatory agencies.
This is not the first time ICD 10 has been delayed by a year; ICD 10 was also delayed from October 1st, 2012 to October 1st, 2013. The rationale behind the previous delay was allowing providers and other entities more time to prepare for the impending change. Now the industry is facing yet again another delay, this time introduced under legislation with a Sustainable Growth Rate patch.
Regulatory Unrest: An Unclear Message
Regardless of motive, the ICD 10 delay is agitating the healthcare industry. Providers, plans, and vendors alike have spent dedicated time and resources gearing up for the big change. For those who have been leading the transition by implementing new technology, hiring more coders, and training existing staff – the decision to delay is discouraging. It negates compliance initiative and reforming the healthcare industry, instead legislators are focusing on patching the economy instead of moving forward.
It also sends a message that it is difficult to gauge when regulatory compliance is going to occur. When changes like this happen, everyone in the industry has to immediately adjust their course of action. Information has to be distributed to employees, policies have to be adjusted, and new plans of action must be formed. This is asking a great deal of the compliance teams, as flexibility is not often an attribute of providing a clear and consistent message to the employee base. Compliance teams will have to decide if they will go ahead with their current initiatives or adjust their course of action to meet current industry practices.
A Proactive Stance Towards Regulatory Change
Policy collaboration and organizational cohesion have become the cornerstones to keeping up with continuously changing regulatory conditions. Ask any compliance team, policies and procedures take some time to draft, distribute, and implement into the company culture. With changing policy, especially at this level, it becomes even more important to make sure organizational policies are updated on time and all operational managers are able to collaborate during policy creation. Merely creating policies in reference to changing regulatory conditions is a recipe for disaster, operational managers need to have say in how working conditions reflect regulatory conditions.
From a technology standpoint, time stamping and version control are also going to be necessities. Employees will need to be notified of policy change at the time that it happens and a record should be kept of the time and date that the employee acknowledged a particular policy. Policy audit trails with version control and time stamping also need to be in place; these time stamps will become increasingly important as there will need to be a record as to what policies were in effect during which parts of regulation. Using the ICD 10 example, policies or procedures include coding reimbursement processes before and after the organizational transition to ICD 10.
Overall the transition to move from ICD 9 to ICD 10 is an industry changer, whenever it occurs, 2014 or 2015. Organizations can only move forward, either choosing to put off their transitory efforts or to just continue with their current plan as if the delay never occurred. Regardless, the key to a cohesive and flexible compliance team is providing the tools, processes, and resources that are necessary to respond to changes in regulatory conditions.
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