After the senate vote on HR 4302, I sent an email to the CIOs of payers and providers in Massachusetts, suggesting that we need to capture the millions spent locally in ICD-10 preparations before mothballing our projects. I suggested that we should continue with testing and go live with as much technology as we can in 2014, minimizing risk to our revenue cycles. Here are some of the responses I received, edited to protect anonymity:
"It would be nice if a couple of us in Mass. could at least say we completed testing and validation and next year we will just regression test."
"I am completely supportive of us maintaining momentum to protect the investments to date. I was also thinking through the ICD-10 transition and potential to down coding to ICD-9 until Oct. 2015. This would require a lot of testing to validate that there is no revenue risks related to the coding conversion. I am not sure if the teams would want to invest the time in that exercise but would support the evaluation process if there is support from coding and finance departments."
"I agree if we could keep provider/payer testing going that would be good. It would also be great if we could get native coding from providers versus using a tool to get manufactured data. This doesn't give us a very good test. I don't agree with accepting ICD-10s and mapping to ICD-9. This concept introduces too much risk and it's additional work that we've have to take on. I wouldn't be able to get internal buy-in on this approach."
"We are still discussing internally but I had assumed we would continue with the current test plan. I am not sure we will continue the same level of testing efforts after Oct. 1, 2014."
Technically, Oct. 1st, 2015 is not the new date, it is the earliest date. We could lobby our legislators to rescind the move to ICD-10 altogether and work towards ICD-11 in 2018.
On April 7, the CIOs will have a community-wide planning call. I’m hopeful that we’ll complete our 2014 ICD-10 projects, do end-to-end testing, and then stand ready to go live fully with ICD10 in the future without significant additional work.
Although I know that many small practices were not ready for ICD10, the majority of hospitals and payers were ready for 2014. A delay in 2013 may have been helpful, but a delay in 2014 is just going to cost hospitals more as timelines and consulting engagements are extended.