ICD-10 Delayed. What Hospices Should Do

Everyone was counting down until October, 2014.  The US healthcare community had been steadily preparing – although perhaps not without some grumbling and complaining along the way –for the implementation of ICD-10.  ICD-10 ­would happen on time on October 1 we were told – we would not experience another ICD-10 delay.

Then “April Fools” happened.

On April 1, 2014 President Obama signed into law the “Protecting Access to Medicare Act of 2014.” The main component of the law was a one year “patch” in the SGR (Sustainable Growth Rate, which impacts how much physicians are reimbursed by the Medicare program).  But tucked deep inside the bill was a single sentence (Section 212), which directed the US Department of Health and Human Services to delay until at least October 1, 2015 the implementation of planned transition to ICD-10.

So it seems that hospice providers have at least a year’s reprieve for the  implementation deadline (at least for this current ICD-10 delay).

But the delay in implementation doesn’t mean that hospice providers should slow down or discontinue their preparation efforts.  So what does the ICD-10 delay mean for hospice providers and how should they move forward with their ICD-10 planning?  Here are some suggestions.

What is the new deadline?

Although the law stipulates that DHHS cannot implement ICD-10 before October 1, 2015, it doesn’t stipulate exactly when the conversion will take place.  That decision will be left up to DHHS and thus far no new specific deadline has been set.  Hospices need to remain vigilant to make sure they don’t miss the announcement of the new deadline.  But until the new deadline is announced, hospices should assume and prepare as if October 1, 2015 is the new ICD-10 conversion date.

Stretch, but don’t stop

After the announced delay, hospices are encouraged to pause a moment, take a deep breath… and then keep right on working.  Organizations should work to maintain their forward momentum, even if it means adjusting your internal calendar and stretching out key milestone dates.  Once a new deadline is set, it may be helpful to work backwards from that point, considering the current state of your projects and preparedness. The advice here is not to stop and try to restart the project again in six months but to keep on plowing forward.  Organizations that do so are likely to be in much better shape when the new deadline rolls around.

Use the extra time to train and to test

It’s well known that the ICD-10 code set brings with it a truckload of new codes and new coding procedures.  Hospice providers should use the extra time caused by the delay to thoroughly teach and train their staff on the new coding system.  For example, clinicians will need to consider how to crosswalk their most common ICD-9 hospice diagnosis codes into IDC-10. Hospices may decide to use the extra time to bring on new staff (such as a certified coder) or evaluate the possibility of outsourcing their coding.

Hospices should also renew their testing efforts, ensuring their systems can support ICD-10.  This includes continuing conversations with software vendors, clearinghouses, payers and other partners to ensure on-time compliance with the new deadline.  The extra delay may even provide the opportunity for some providers to dual-code – another suggestion that may limit interruptions in reimbursements when the ICD-10 switch is flipped.