Managing an ICD-10 implementation among other larger and costly initiatives is also challenging, says Shereen Martin, RHIA, MSA, director of HIM and privacy officer for Washington County Hospital in Hagerstown, MD. Many hospitals nationwide will be focusing their efforts on recovery audit contractors, leaving few resources to devote to ICD-10, she adds.
Washington County Hospital is currently in the midst of deploying an EHR in its ED, implementing computerized physician order entry, and preparing for complex RAC reviews in August. As with most other hospitals, Washington County must first determine how it will fare with RACs before deciding how soon it will turn its attention to ICD-10, she says. "Coding managers will be dealing with both issues [RACs and ICD-10]."
Starting as early as you can—particularly from a budgeting perspective—will only help you in the long run, Nachimson says. "If you want to get this done, you need to do some of it now and some of it in each of the next few years," he adds. "Otherwise, you're going to get to 2012 and be faced with such a large resource or budget need that you're not going to be able to make it."
As hospitals begin to think about how to qualify for EHR incentives under ARRA, they also need to be asking how vendors plan to accommodate ICD-10. Hold vendor representatives responsible for their own portion of the timeline, Nachimson says.
Although vendors may be able to provide some education, hospitals need to think about how ICD-10 will affect their business processes. For example, how will hospitals ensure that physician documentation will be specific enough to meet ICD-10 standards? How might quality measures or clinical guidelines change to accommodate the new codes? Will health plan coverage for certain tests change so that only certain severe conditions will be deemed medically necessary? These questions are only the tip of the iceberg in terms of potential ramifications of ICD-10, Nachimson says.