Author Archive

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

December 18, 2010

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.


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:


What a Year in HIM!

November 11, 2010

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)?

October 1, 2010

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

August 13, 2010

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-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

Feds propose stronger patient privacy rights

July 11, 2010

We just saw this on the HIM Circle facebook page (


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:

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

June 4, 2010

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…

Your First Big HIPAA Privacy Breach? 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

February 19, 2010

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. 


For consulting help or free peer support, visit to learn how we can make a difference, together.

January CMS Updates

December 19, 2009

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

Here is a link to the January Integrated OCE

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

Here is a link to the Consult EM changes information

New Solution for Retiring Doctors Now Available

August 3, 2009

Retiring Doctor .com a service for Physicians and Doctors looking to retireThe team at Clear Medical Solutions recently merged into their portfolio of solutions to the healthcare industry. provides a unique “One Stop Shop” solution for the host of issues that doctors face when closing their practice.  

The consultants at Clear Medical Solutions will team with the administrative experts at to offer an amazing experience that will make retiring easier for the thousands of physicians that are retiring in the coming years.

Not only will the Doctors get consierge level service, but the Patients needing medical records and other information from their retired doctor will get an easy solution that won’t interupt their former doctor.

Visit the website to see more:

On Facebook:

On Twitter:

So…what do you think?

Healthcare Cost Reduction Initiative

May 23, 2009

This past week healthcare executives have vowed to take a semi-united front to align with President Obama’s goals to lower the cost of healthcare. Armed with the goal of saving $2 trillion over the next 10 years, industry leaders have volunteered to reduce the growth rate of national health care spending care costs by 1.5moneytab% every year.  

Fox News reported that six leaders of the health care industry penned a letter to Obama stating that: “We will do our part to achieve your administration’s goal of decreasing by 1.5 percentage points the annual health care spending growth rate, saving $2 trillion or more. This represents more than a 20 percent reduction in the projected rate of growth.”

Though this declaration is advantageous to Americans, it is not without its benefits to health care leaders.  Namely, “they hope to stave off new government price constraints that might be imposed by Congress or a National Health Board of the kind favored by many Democrats” (


One reason that healthcare costs are so out of control is due to the lack of productivity.  In a report being sent to Congress on Monday, two research and advocacy groups, the Center for American Progress and the Democratic Leadership Council, say that productivity growth in health care has lagged behind that of other industries.  The government could save nearly $600 billion over the next decade if the health care industry increased its productivity growth by 1.5 to 2 percentage points a year, said the report, by David M. Cutler, a Harvard economist.

Taking a cue from industry leaders, members of the medical and insurance sector are also eagerly waving their hands to join the Lower Health Care Cost Team.  But before they receive the MVP award it is important to notice their timing.  Some Washington officials claim that the plan is for them to give in to some cost control concessions presented by the Obama Administration in an effort to thwart the implementation of a public heath care plan and to have at least some say over the direction of the overhaul.  But history might repeat itself: “the health care industry’s offer to slow the rise in health care costs mirrors a trend that goes back to 1993, when President Clinton launched his reform effort. The rate of health care inflation had been in the double digits before that and it begun rising after the Clinton administration’s effort failed, reaching its most recent peak of 9 percent in 2002.  In 2006, healthcare consumed 15% of gross domestic product” (

Some leaders believe that improving the use of EHR technology will result in increase productivity and decreased costs.

What do you think?


About The Author:

Kristen Mirsky is a Staff Writer with the Clear Medical Solutions Communication Team.  Her work is regularly shared on the Clear Medical Agency newsletter and the blog.  

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