How Should Medicaids Respond to the ICD-10 Postponement?

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“HHS Secretary Kathleen Sebelius Announces Delay of ICD-10 until October 1, 2014” was the title of a CMS press release dated April 9, 2012. The news came in response to political pressures to postpone the original October 2013 deadline and ongoing industry concerns related to the bumpy transition to the new 5010 versions of electronic transactions. This paper outlines three key actions states can take to ensure the continuity of their ICD-10 transition efforts in the 'extra year.'

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How Should Medicaids Respond to the ICD-10 Postponement?

  1. 1. How Should Medicaids Respond to the ICD-10 Postponement? State Medicaid Agencies Face Challenges andOpportunities as Regulatory Mandates and Coverage Expansions ConvergeThis white paper contains data that shall not be duplicated, used, or disclosed in whole or in part without the express permission of Cognosante. Copyright© 2012.
  2. 2. How Should MEDICAIDS Respond to the ICD-10 Postponement October 2012 ContentsHOW SHOULD MEDICAIDS RESPOND TO THE ICD-10 POSTPONEMENT? ................................................ 1MEDICAID CHALLENGES ................................................................................................................................ 1WHAT CAN STATES DO WITH THE “EXTRA” YEAR .......................................................................................... 2WHAT COGNOSANTE CAN DO FOR YOU.......................................................................................................... 2 Use or disclosure of data contained on this sheet is subject to the restriction on the title page of this white paper. ii
  3. 3. How Should MEDICAIDS Respond to the ICD-10 Postponement October 2012 HOW SHOULD MEDICAIDS RESPOND TO THE ICD-10 POSTPONEMENT? State Medicaid Agencies Face Challenges and Opportunities as Regulatory Mandates and Coverage Expansions Converge“HHS Secretary Kathleen Sebelius Announces Delayof ICD-10 until October 1, 2014” was the title of aCMS press release dated April 9, 2012. The newscame in response to political pressures to postpone theoriginal October 2013 deadline and ongoing industryconcerns related to the bumpy transition to the new5010 versions of electronic transactions.An August 24 announcement made the one-yearpostponement official. The goalposts have beenmoved, but now they are firmly set in place.Medicaid ChallengesWhile the ICD-10 mandate applies to all health careproviders and health plans, public and private, theadditional layers of budget constraints and the expansion of coverage add unique challenges to StateMedicaid Agencies (SMAs) and the contractors who support them.ICD-10 comes as a complicating – but necessary – addition to an environment also driven by: Expansion of the covered patient population and the implementation of Health Information Exchanges (HIX) under the Affordable Care Act (ACA) Federally-mandated initiatives such as Health Insurance Exchange (HIE), and Electronic Health Record (EHR) Incentive program under the American Reinvestment and Recovery Act (ARRA) Updates to the Medicaid Information Technology Architecture (MITA) framework and “Seven Standards” Enhanced Funding RequirementsWhile federal funding isavailable for the variousinitiatives, dynamics betweenthe federal and stategovernment can complicatethe financing picture as statebudgets and human resourcesare strained in the currenteconomy. Moreover, as muchas the federal policies andprograms arise from acommon understanding of thecost and quality benefits ofhealthcare IT, the regulationsand directives do not connectthe dots. By necessity, theintegration and coordinationof the programs need to takeplace at the state level. Use or disclosure of data contained on this sheet is subject to the restriction on the title page of this white paper. 1
  4. 4. How Should MEDICAIDS Respond to the ICD-10 Postponement October 2012What Can States Do With the “Extra” YearFollowing are three actions states can take to ensure the continuity of their ICD-10 transition efforts:1. Continue efforts underway and allocate extra time for testingWhile even the mention of a delay tends to impact forward momentum, SMAs should stay focused onefforts underway, heeding the advice of CMS and industry experts to allocate the additional time fortesting. Some states are sticking to their original implementation schedule, planning for a full year ofprovider outreach and end-to-end testing2. Pursue funding from CMSState funding will remain constrained, but CMS has encouraged SMAs to continue to submit AdvancedPlanning Documents (APD) for review. Revisit prior plans and estimates to ensure you have resources inplace for the longer haul.3. Integrate rather than isolateICD-10 projects, and any downstream effects of the delay, should be re-assessed in light of otherinitiatives underway. New MMIS procurements, HIE, HIX and the enrollment of new beneficiaries underthe ACA expansion may all be impacted by the timing of ICD-10, both in terms of data requirements andcompetition for scarce resources. Conventional impact analyses tends to proceed from the “as-is” state toa “to-be” state; however, with many systems being simultaneously developed and deployed, there must bean appreciation for how these multiple “yet to be” systems need to work together and how they willenhance value. Active outreach and coordination between stakeholders in the implementation efforts iskey.What Cognosante Can Do For YouCognosante’s Standards Practice professionals have conducted and implemented full-scale ICD-10remediation projects for SMAs and other health plans, both public and private. If you are starting late, wehave the been there/done that expertise to help you get up to speed quickly. For SMAs who have alreadyconducted an enterprise-wide ICD-10 impact assessment and are looking for support in the next phase ofthe process, Cognosante has trained and experienced staff ready to assist with the critical resourcesneeded for a successful remediation effort. Translation Services The "bad news" of initial ICD-10 assessments is that there is no black box technical solution that allows you to pour ICD-9 codes in on one side and instantly retrieve equivalent ICD-10s out the other. The good news is that taking a hard look at medical policies, edits, audits and pre-auth rules can yield cost savings and service enhancements. Cognosante’s “policy first” translation services focus on using sophisticated tools to capture the meaning and clinical intent of your existing policies and business rules so they can be consistently interpreted in both ICD-9 and ICD-10. Testing/Test Planning/Approach Unlike prior transaction-based HIPAA mandates such as NPI and 5010/D.0, the ICD-10 mandate offers no "parallel processing" window. According to the rule, all dates of service (DOS) prior to the Compliance Date must be ICD-9 and only ICD-9; all DOS on or after the Compliance Date must be ICD-10 and only ICD-10. This industry-wide “Big Bang” implementation adds to the level of complexity and reinforces the importance of hands-on, end-to-end testing across the enterprise and with external trading partners. Cognosante’s industry savvy and testing services experience will help you plan, establish and implement a testing solution that verifies the use of the new codes, not just their length and format. Use or disclosure of data contained on this sheet is subject to the restriction on the title page of this white paper. 2
  5. 5. How Should MEDICAIDS Respond to the ICD-10 Postponement October 2012Provider OutreachThe detail that all health plans, public and private, must remember is that all their diagnosis andprocedure data originates with providers - if providers dont capture it, health plans cant use it; if thatcapture process isnt accurate, the data wont be reliable. Its understood that there will be atransitional period during which both groups will become accommodated to working with the newcoding systems, but that only adds to the importance of working together prior to the transition. MostMedicaid providers also serve patients covered by other health plans, such as Medicare, Blue Cross orcommercial plans, who may be providing ICD-10 training and guidance. But other providers, whorely on Medicaid exclusively, may be looking to a particular SMA for virtually all of their ICD-10guidance. Cognosante helps you leverage your existing communications resources to deliver timely,accurate, and consistent provider messaging for the ICD-10 transition. Use or disclosure of data contained on this sheet is subject to the restriction on the title page of this white paper. 3

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