The following is some email comments from Richard D. Tomlinson, RN and Founder of Nuclei Health Consultancy, in reply to my post on ICD-10 Business Areas of Concern. They weren’t intended for posting, but I thought they were quite insightful and so Rick gave me permission to share them.

Wonderful post (as always) relative to our issues driving yet another future-state condition in healthcare, namely ICD-10. If I may, I would like to approach ICD-10 from another perspective.

While everyone knows that ICD-10 is (eventually) a reality for U.S. healthcare organizations, I convey there is much more to addressing ICD-10 CM/PCS than simply “making the conversion” or “dual coding” as benchmarks towards success. My own list of preparedness relative to ICD-10 is somewhat different than yours and designed to combine strategic as well as tactile integration to address ICD-10 CM/PCS.

1. Clinical Documentation Improvement process.
2. Roust education via clinical case studies showing the BUSINESS CASE IMPACTS downstream of inadequate clinical documentation & coding.
3. ICD-10 Gap analysis current-state to include clinical and financial gaps.
4. Validation testing of via test patient build/coding.
5. EHR optimization specific to ICD-10 (MORE is NOT BETTER).
6. Evaluation of CAC (Computer Assisted Coding).
7. Evaluation of alternative coding resources (e.g. outsourcing).
8. Viability Reporting to C-Suite (not simply “on track” reporting. It’s not a project; it’s an initiative. Establish and report on critical success factors).
9. Establishment of robust clinical documentation/ICD-10 ad hoc committees. Include CMIO or provider champion/HIM/financial/quality/informatics/IT
10. Establishment of robust analytics to reverse engineer denials (where/what/whom) and specific identification of mitigation actions (e.g. education, CDI, etc) and processes.

The bottom line in my view is this; any organization treating ICD-10 as a “conversion” is headed for significant problems in terms of denials and missed revenue capture. ICD-10 should be viewed by the C-Suite specifically as a platform to improve patient safety/care, to improve clinical documentation, improve quality measures, and a specific strategy to reduce costs and increase potential revenue capture. Properly deployed, ICD-10 initiatives can actually accomplish all of this. My suggestion to my clients is to approach ICD-10 strategically, not merely as a conversion process, and develop a plan incorporating the measures I’ve indicated above. Serious Measurement of these factors will be required, regardless of facility type or size.

Lastly, I think some organizations are mistakenly treating this not only as a “conversion” but also siloing this to the small HIM or coding backroom as a problem for the coders. This approach will paint the coders into an unfortunate corner, and may create a situation where optimum revenue capture opportunities are lost…forever. For example, improper coding of a patient acquiring bed sores while inpatient may result in denials and reduce certain quality scores inappropriately. When you consider that coding is the final life blood touchpoint of revenue generation, it’s time for the C-Suite to leverage ICD-10 as a strategy to place importance of improved clinical documentation as a business case, and measure the clinical, …read more