Don’t Forget to Budget for ICD-10 in 2011

Yes, we have until 2013.  However, the more I take part in ICD-10 planning committees, the more I realize that this is going to take a huge amount of preparation time.

It’s time to get started now.

Obviously, since we’re still in the process of training the trainers on ICD-10, I’m not referring to training your team on the actual ICD-10 codes.  But, since ICD-10 will place a significant emphasis on specificity and anatomy, I do believe that it is time to start training your providers and coders on:

1. Documenting every detail  (providers)
2. Understanding what they will be reading (coders)

This means some form of Clinical Documentation Improvement (CDI) program across your organization.  It also means training or retraining your coders on Anatomy.

These things take tremendous amounts of time, and the time to train on the actual codes is quickly approaching.  The best way to avoid a training logjam at the end is to begin soon.  (Logjams in coding tend to be a major financial problem)

The time is now.  Don’t forget to budget for it.

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About the Author:

Aaron is one of the leaders of the HIM Circle movement and former HIM Director at multiple hospitals.  Join the free HIM Circle for further discussion about ICD-10 on these various forums:

• http://facebook.com/HIMCircle
• http://LinkedHIM.com
• http://twitter.com/HIMCircle

What a Year in HIM!

Happy HIT Week!  The past year has been a tough one!

We thought it would be great to take a moment and consider all the issues we’ve dealt with  together over the last year.  We tackled RAC’s, dealt with the new HITECH and HIPAA rules, handled coding changes, many of us continued mastering our EMR projects, and we’re all starting to learn about and prepare for ICD-10.

The nice thing is that over the last year, we haven’t had to do it alone.  Through the HIM Circle, we’ve answered more than 200 peer questions on our free peer support forums on facebook, Linkedin, and twitter.  It’s been amazing!

Thank you for being a part of the HIM Circle, and we can’t wait to see what the next year has in store for us all. 

Enjoy the week!

Motivation for Clinical Documentation Improvement (CDI)?

As we continue to build our Clinical Documentation Improvement (CDI) program in preparation for ICD-10 and a continued increase in audits (RAC, MIC, and Commercial Insurance), we’ve been doing a lot of discussing and research related to what objectives a CDI program might have.

• Is it to increase reimbursement through assignment of CC’s and MCC’s?
• Is it to improve coding productivity?
• Is it to reduce the potential risk from recovery audits?
• Is it to improve patient care?

Or, should it be a combination of the above?  Glenn Kraus, RHIA, CCS, CCS-P, CPUR, C-CDI, CCDS had some interesting thoughts on why we shouldn’t only focus on the reimbursement. 

There is almost always an opportunity to improve clinical documentation in any medical record chart from both a resource intensive reimbursement standpoint and quality of care and clinical outcomes standpoint. 

But just as the profession is gaining momentum and increased recognition in the business facet of healthcare, we have reached a crossroads and may be going down the wrong path.

The crossroads

For those of us who have been in the clinical documentation improvement arena for a long time, it is eye-opening to view the advertisements and promotional materials for clinical documentation improvement projects readily available at trade shows and appearing in prominent trade journals. The common promotional theme is increased reimbursement for the hospital, which is not surprising given the fact these clinical documentation improvement programs are marketed strictly on the basis of “reimbursement enhancement.”

Let’s not kid ourselves, every healthcare expenditure that is not direct patient care related must provide for a reasonable chance of return on investment, contributing to the organization’s financial performance in some form or fashion, whether it be additional revenue or at least cost avoidance.  But there has been some talk in the industry that some firms have worked into their CDIP contracts a guarantee of specified amount of increased reimbursement for the hospital with the implementation of their programs. 

The aftermath

Clinical documentation improvement programs can be structured to meet the documentation requirements required in the health record to financially sustain the hospital from a financial accounting and quality of care reporting perspective.  How the program is structured can dictate success or failure in the rollout and acceptance of the program by physicians and other ancillary service providers.

In speaking with a fellow colleague recently, I heard a valid concern that is worth mentioning regarding where the CDIS profession is now, and where it may be going. Once again it may be going down the wrong route. My colleague pointed out that in some instances, the clinical documentation improvement specialists appear to be focusing on reviewing the record solely for identification and documentation of “missed CCs and MCCs,” almost as if they were “CC/MCC scroungers.”

The very idea of CDIPs being promoted primarily as reimbursement mechanisms perpetuates and drives the ever-increasing viewpoint of CDIS as CC/MCC identifiers. In order to be directed down the right path, we need to stay attuned to the mission of the profession, which is to affect positive change in physician’s patterns of clinical documentation over the long term through provisions and actions of continued physician education. This relentless pursuit of physician clinical documentation education embraces a holistic approach with an emphasis upon the direct correlation between clinical documentation and the continued business financial viability of the both the hospital as well as the physician. A primary focus upon “getting that CC/MCC” documented in the record represents a very small cross sectional piece of what the CDIS can fundamentally contribute to a successful program.

 

Which way do you think it should go?

We are at the crossroads for CDI.  The direction we as an industry decide to take will guide the future.  Decisions made today will impact all of us in HIM and finance both tomorrow and well into the future.

An Abridged Guide to ICD-10

As you probably have heard by now, on October 1, 2013, the ICD-9 code sets used to report medical diagnoses and inpatient procedures will be replaced by ICD-10 code sets.  We’ve compiled information directly from the CMS website to help provide a basic introduction and some steps to help prepare for ICD-10. 

In the future, we’ll be posting more updates.  If you’d like to have those updates sent to you, simply subscribe on the right side of blog’s home page (Click the word “Clear” above to get there).

ICD-10

ICD-10-CM/PCS (International Classification of Diseases, 10th Edition, Clinical Modification/Procedure Coding System) consists of two parts:

1. ICD-10-CM for diagnosis coding
2. ICD-10-PCS for inpatient procedure coding

ICD-10-CM is for use in all U.S. health care settings. Diagnosis coding under ICD-10-CM uses 3 to 7 digits instead of the 3 to 5 digits used with ICD-9-CM, but the format of the code sets is similar.

ICD-10-PCS is for use in U.S. inpatient hospital settings only. ICD-10-PCS uses 7 alphanumeric digits instead of the 3 or 4 numeric digits used under ICD-9-CM procedure coding. Coding under ICD-10-PCS is much more specific and substantially different from ICD-9-CM procedure coding.

 

Why?  The transition to ICD-10 is occurring because ICD-9 produces limited data about patients’ medical conditions and hospital inpatient procedures. ICD-9 is 30 years old, has outdated terms, and is inconsistent with current medical practice. Also, the structure of ICD-9 limits the number of new codes that can be created, and many ICD-9 categories are full. 

 

Steps to Prepare for Version ICD-10

• Begin preparing now for the ICD-10 transition to make sure you are ready by the October 13, 2013, compliance deadline. The following quick checklist will assist you with preliminary planning steps.
• Identify your current systems and work processes that use ICD-9 codes. This could include clinical documentation, encounter forms/superbills, practice management system, electronic health record system, contracts, and public health and quality reporting protocols. It is likely that wherever ICD-9 codes now appear, ICD-10 codes will take their place.
• Identify potential changes to work flow and business processes. Consider changes to existing processes including clinical documentation, encounter forms, and quality and public health reporting.
• Assess staff training needs. Identify the staff in your office who code, or have a need to know the new codes. There are a wide variety of training opportunities and materials available through professional associations, the HIM Circle, online courses, webinars, and onsite training. If you have a small practice, think about teaming up with other local providers. You might be able, for example, to provide training for a staff person from one practice, who can in turn train staff members in other practices.
• Coding professionals recommend that training take place approximately 6 months prior to the October 1, 2013 compliance date.
• Budget for time and costs related to ICD-10 implementation, including expenses for system changes, resource materials, and training. Assess the costs of any necessary software updates, training and related expenses.
• Conduct test transactions using ICD-10 codes with your payers and clearinghouses. Testing is critical. Check to see when they will begin testing, and the test days they have scheduled.

See the “Compliance Timeline” below for important stages of implementation for ICD-10 and the Version 5010 that goes with it.

 

DECEMBER 31, 2010

• Internal testing of Version 5010 must be complete to achieve Level I Version 5010 compliance

JANUARY 1, 2011

• CMS begins accepting Version 5010 claims
• Version 4010 claims continue to be accepted

DECEMBER 31, 2011

• External testing of Version 5010 for electronic claims must be complete to achieve Level II Version 5010 compliance

JANUARY 1, 2012

• All electronic claims must use Version 5010
• Version 4010 claims are no longer accepted

OCTOBER 1, 2013

• Claims for services provided on or after this date must use ICD-10 codes for medical diagnosis and inpatient procedures

  

To discuss ICD-10 with your peers, visit http://www.HIMfacebook.com

Feds propose stronger patient privacy rights

We just saw this on the HIM Circle facebook page (http://www.facebook.com/HIMCircle):

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The U.S. Department of Health and Human Services (HHS) proposed a new federal healthcare information privacy rule yesterday that would expand patients’ rights to access their information and restrict certain types of disclosures of protected health information to health plans, according to InformationWeek.

The proposed rule is part of the Obama administration’s plan for every citizen to have an electronic medical record by 2014.

The changes are also a response to the Health Information Technology for Economic and Clinical Health (HITECH) Act, which requires HHS to change the Health Insurance Portability and Accountability Act of 1996 (HIPAA) rules by strengthening the privacy and security protections for health information.

The proposed rule would strengthen and expand HIPAA privacy, security and enforcement rules by:

• Expanding individuals’ rights to access their information and to restrict certain kinds of disclosures of protected health information to health plans;
• Requiring business associates of HIPAA-covered entities to follow most of the same rules as the covered entities;
• Setting new limitations on the use and disclosure of protected health information for marketing and fund raising; and
• Prohibiting the sale of protected health information without patient authorization.

For more information check out the new HHS Website:
http://www.hhs.gov/healthprivacy/

Your First Big HIPAA Privacy Breach? (via Clear Matters)

For anyone concerned about having to notify the media and HHS under the Breach Notification Rules, this story is quite troubling. Imagine if your HIM Department had its old copier/printer purchased by criminals?

This story sheds some light on that scenario…

As the HIM Circle initiative continues to expand, the peer support community is proving to be more helpful than ever as changes to HITECH, HIPAA, and ICD-10 come along.  One of the big issues emerging from our research with HIPAA Privacy and the new breach notification  rules relates to the use of copy machines that your department or traditional ROI vendors may be using.  This short report by CBS News shows how one covered entity (Affinity Healt … Read More

via Clear Matters

Update: Submitting Notice of a Breach to HHS

The breach notification interim final rule requires covered entities to provide the Secretary with notice of breaches of unsecured protected health information (45 CFR 164.408).  The number of individuals affected by the breach determines when the notification must be submitted to the Secretary.

Please review the instructions below for submitting breach notifications.

Breaches Affecting Fewer than 500 Individuals

For breaches that affect fewer than 500 individuals, a covered entity must provide the Secretary with notice annually.  All notifications of breaches occurring in a calendar year must be submitted within 60 days of the end of the calendar year in which the breaches occurred.  Notifications of all breaches occurring after the effective date in 2009 must be submitted by March 1, 2010.  This notice must be submitted electronically by following the link below and completing all information required on the breach notification form.  A separate form must be completed for every breach that has occurred during the calendar year.  

If a covered entity that has submitted a breach notification form to the Secretary discovers additional information to report, the covered entity may submit an additional form, checking the appropriate box to signal that it is an updated submission.

Breaches Affecting 500 or More Individuals

If a breach affects 500 or more individuals, a covered entity must provide the Secretary with notice of the breach without unreasonable delay and in no case later than 60 days from discovery of the breach.  This notice must be submitted electronically by following the link below and completing all information required on the breach notification form.

If a covered entity that has submitted a breach notification form to the Secretary discovers additional information to report, the covered entity may submit an additional form, checking the appropriate box to signal that it is an updated submission. 

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For consulting help or free peer support, visit http://www.HIMCircle.com to learn how we can make a difference, together.

January CMS Updates

Below are January CMS updates compiled by Sheila at the RWHC:

Here is a link to the January Integrated OCE

http://www.cms.hhs.gov/transmittals/downloads/R1872CP.pdf

Here is the link to the January PPS updates – for both the Medicare Benefit Policy Manual and Claims Processing Manual

http://www.cms.hhs.gov/transmittals/downloads/R116bp.pdf

http://www.cms.hhs.gov/transmittals/downloads/R1871CP.pdf

Here is a link to the Consult EM changes information

http://www.cms.hhs.gov/transmittals/downloads/R1875CP.pdf

Health Information Bill of Rights

Consumers are familiar with HIPAA and aware that it protects access to personal health information at a national level.  Consumers may be surprised to discover that only “covered entities” (healthcare providers, health plans and health clearinghouses) are required to comply with these regulations.  Many entities that access and use the same information are not bound by the same regulations.  Each state has its own regulations regarding health information.  These regulations vary and there is no uniform national standard.

As the country moves closer and closer to full digitalization of all health information, security becomes a greater concern and patients deserve to know who has access to their information and how their information is protected.

In light of this, the American Health Information Management Association (AHIMA) designed a Health Information (HI) Bill of Rights as a model for protecting personal health information.  The Bill contains seven rights “for the sole purpose of protecting healthcare consumers”:

1. The right to access your health information free of charge
2. The right to access your health information during the course of treatment
3. The right to expect that your health information is accurate and as complete as possible
4. The right for you or your personal representative(s) to know who provides, accesses, and updates your health information, except as precluded by law or regulation
5. The right to expect health care professionals and others with lawful access to your health information to be held accountable for violations of all privacy and security laws, policies, and procedures, including the sharing of user IDs and passwords
6. The right to expect equivalent health information privacy and security protections to be available to all healthcare consumers regardless of state or geographic boundaries or the location (jurisdiction) of where the treatment occurs
7. The right to the opportunity for private legal recourse in the event of a breach of one’s health information that causes harm

Vera Rulon, AHIMA president, said the bill was made necessary by “Repeated abuses of access, accuracy, privacy and security of the most basic rights of individuals whose trust has been betrayed and dignity compromised.”  The seven point bill eases patient’s fears about security by increasing transparency and encouraging providers to give the strictest protections to personal health information.

Posters featuring the HI Bill are already making their way into health facilities and physicians offices.  Wallet sized cards with the Health Information Bill of Rights Preamble on one side and the seven rights on the other are being developed.  The card will give consumers easy access to their HI rights whenever or wherever they are.

Unfortunately at this time the HI Bill of Rights is only a model.  It has not been signed into law and until it is or something comparable is, there will continue to be fears and concerns about the safety of personal health information.  However, the HI Bill of Rights is a step toward making consumers more informed about their health information and confident in how that information is managed; it is a step in the right direction.

Questions: What do you think about the HIM Bill of Rights?  Do you think there are any key points missing?  

About the Author: Erika Christenson is a Staff Writer with the Clear Medical Solutions Communication Team.  Her work is regularly shared on the Clear Medical Agency newsletter and the ClearNursingMatters.com blog.

Resources:
AHIMA Health Information Bill of Rights http://library.ahima.org/xpedio/groups/public/documents/ahima/bok1_045343.pdf

AHIMA Rights Bill Sets Ideal Standard for Protecting Consumer Health Information http://www.ahima.org/press/HIBOR.asp

The Clear Medical Network

With rapid improvements in technology and communication, social networking is thriving and full of potential.  Sites like Facebook, Twitter and LinkedIn are known among all people, young and old.  As the dynamics of online communication are growing, companies are adapting to the trends.  One example is the Clear Medical Network.  

It was formed to provide an avenue for networking among all different healthcare professionals as well as provide career opportunities through consulting projects, leadership positions, and per diem work to all its members.  It’s also a great resource if you are looking for full time or per diem coders or transcriptionists in your area at a wholesale rate.  

Registered members are also informed of any upcoming fun events in their area.  One upcoming event is  a really great deal for an 8 day/7 night cruise next year to the Mexican Riviera! 

In case you are wondering, joining the network is free and takes less than a minute.  Once registered, members are informed of different forums they can join to network with other healthcare professionals within HIM as well as other areas of healthcare. 

If you are interested in joining, the site is www.ClearMedicalNetwork.com.  

This is definitely a new way to keep all healthcare professionals connected in one primary location.  Personally, I’m really excited about all the opportunities this could provide!

Questions: What do you think of the Clear Medical Network?

About the Author: Sarah Fore is a Staff Writer with the Clear Medical Solutions Communication Team.  Her work is regularly shared on the Clear Medical Agency newsletter and the ClearNursingMatters.com blog.