Implementation: ICD-10 Lessons Learned

EDITOR’S NOTE: George Vancore appeared during a recent edition of Talk Ten Tuesdays focused his report on lessons learned during the implementation of ICD-10 in preparation for ICD-11. This article is a summary of his remarks.

When Chuck Buck recently asked whether I could summarize Florida Blue’s ICD-10 implementation success in four minutes or less, I told him, probably not! What I can do, though, is provide you with three simple things that we took away from our ICD-10 implementation that you may find valuable.

As some of you may recall, Florida Blue’s ICD-10 implementation was the biggest non-event since Y2K, and it all came down to three simple things:

1. Communication
2. Contingency Planning
3. Testing

These all seem simple enough, but not so fast. Let’s take a quick look at each in more detail.

Communication:
Most of us take a traditional approach to communication by focusing on internal constituents. That’s OK, but recognize that there is a big integrated healthcare system world out there that we depend on to be successful. For example:

1. Do your communication efforts include external entities like business associates, physicians, providers, delegated entities, and vendors?
2. Do you define communication as sending a letter or posting something on your corporate Internet?
3. Is your communication plan sustainable over time, or is it a one-and-done approach?

Well, those tactics just don’t cut it, for several reasons:

• Have you thought about face-to-face conversations?
• Delivering talks at medical associations and societies?
• Hosting workshops?
• What about collaborating with your competitors and doing a monthly call-in teleconference with a roundtable of providers, health plans, vendors, medical professionals, and consultants to share experiences?

Simply put, these sustainable tactics all worked for Florida Blue.  

Let’s turn our attention to the second factor:

Contingency Planning:
This is one area that we tend to ignore until post-implementation when it is too late. So, what did you do during your ICD-10 preparations? Did you even think about “what ifs?”

Given everything that was happening across the healthcare industry on ICD-10 readiness, did you ignore the fact that a subset of your physicians, providers, delegated entities, business associates, or vendors would not be ready? Did you implement ICD-10 with a contingency plan that said, “if you are not ICD-10-compliant, we will reject your claims?” How did that work out for you and your providers? 

What if you built in a contingency plan that enabled you to execute either ICD-9 or ICD-10 at the same time? This became known as “dual-mode processing,” but wait: if we design our systems to operate in dual mode, then aren’t we executing in a “non-compliant” mode? The Centers for Medicare & Medicaid Services (CMS) would not be happy.

• Do you really believe that your regulator would shut you down if you discussed it with them ahead of time?
• Do you really believe that if you documented a corrective action plan with appropriate controls and outreach strategies to work with those physicians and providers to help them get ICD-10-compliant, this would be negated by the regulator?

Let me put it this way: that is exactly what Florida Blue did! We built-in dual-mode processing created a correction action plan and reviewed it with CMS. So, when the implementation date hit, we were operating in dual mode, and it prevented over 12 percent of our electronic transactions from being rejected due to being non-compliant.  

Now, the rest of the story: 45 days later, and after a lot of work with our non-compliant senders, mostly physician practices, we were 100 percent ICD-10-compliant! This is what we meant when we said that our ICD-10 Implementation was a non-event!

Now let’s talk about the last item:

Testing:
We all do testing. We have all tested successfully with external entities that are technically capable, but what about testing with entities that are not as technically astute?

• Do you use a testing environment that has special “test data” that resides in some internal repository somewhere?
• Can you enable physicians, providers, vendor-delegated entities, and business associates to access this environment and its data, for testing purposes?
• What about test data coordination between these entities? Is that even possible?

What about using your existing production environment and real production data for testing purposes? What if I built out a testing environment that contains a copy of production data, and all applicable processing rules? Can you really do that?

Take a step back for a second: if I am dual-mode capable, I can have previously processed ICD-9 claims played back into my environment after they have been ICD-10-coded by the sending entity, and route them to my testing environment!

That is exactly what Florida Blue did, and any sending entity can simply playback an ICD-10-enabled claim that will be routed to my testing platform – we would process and adjudicate the claim, create an 835, and send the information back to the sending entity for their testing.

So, in summary, Florida Blue’s ICD-10 implementation was, again, the biggest non-event since Y2K, and it all came down to three simple things: communication, contingency planning, and testing.