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What Does the ICD-10 Delay Mean for ASCs?

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At the beginning of April, President Barack Obama signed into law the Protecting Access to Medicare Act of 2014. The legislation delayed a 24 percent reduction in Medicare rates for physicians associated with the sustainable growth rate formula as well as ICD-10 implementation by at least one year.

This development in the ICD-10 saga sparked mixed reactions. The American Medical Association, one of the most vocal ICD-10 opponents, issued a surprisingly ambivalent response. While the AMA welcomes the additional time to prepare for ICD-10, it does not feel that the brief delay is worth the price of another SGR patch. On the other hand, vendors have cried out against the delay, citing a CMS statement estimating the delay to cost from $1 billion to $6.6 billion. CMS has yet to release a statement on the now officially inked delay.

Amidst all of the confusion, where do ambulatory surgery centers stand? Angie Hicks, director of product management at SourceMedical Solutions, and Adam C. Hauser, MD, medical director of the Crozer-Keystone Surgery Center at Brinton Lake in Glen Mills, Pa., offer their view points.

Potential setbacks and benefits
CMS assured the healthcare industry the Oct. 1, 2014 deadline for ICD-10 was set in stone, spurring on the mad dash to prepare. The largest downside is for ASCs that poured time and money into preparation, when in retrospect those resources could have been allocated differently.

Angie Hicks"For those facilities that have already started their training program, I could see how this might be viewed as a setback since AHIMA had suggested training begin no more than six to nine months in advance of the implementation date," says Ms. Hicks.

For the most part, the ASC industry seems have to heaved a collective sigh of relief. "We are fine with ICD-10 implementation delay," says Dr. Hauser. "We actually could use the extra time."

The road ahead
The additional time provides ambulatory surgery center leaders the opportunity to map out an effective implementation plan and fine tune any efforts they have made thus far. Steps to take include:

1. Staff training. Regardless of how far an ASC's staff has progressed on training, further preparation remains key. "This additional time may help the ASCs have a smoother transition to ICD-10," says Ms. Hicks. As the deadline grows closer, periodic staff assessments will reveal the progress of training and what remains to be done.

2. Physician education. Physicians are the lynchpin of any ASC's ICD-10 plan. "In order to make this work, you need all the proper codes from the surgeons. This is true of any OR, particularly for an Dr. HauserASC," says Dr. Hauser. "If they don't dictate the level of detail that's required, then someone from billing will need to follow up with them to find out what is missing in order to comply with the new ICD-10 requirements." With the deadline now more than one year out, ASC leaders can take the time to educate physicians on the switch and iron out any potential wrinkles in the process before the actual deadline.

3. Software updates. Vendors have been clamoring to offer ICD-10 solutions; an internal look will let ASC leaders know whether or not their software is ICD-10-ready or requires an update. "One of the big issues is getting the software up-to-date, so that it can support compliance with the new requirements," says Dr. Hauser. "Within our practice we are pushing for that, but we're not there yet."

Software updates will need to accommodate the influx of codes that ICD-10 represents. "I am concerned some ASCs may not upgrade to the versions that provide support for ICD-10 codes timely since the deadline has been pushed out," says Ms. Hicks.
4. Technology upgrades. Not all ASCs have made the switch from paper to electronic, but the impending ICD-10 switch may force the issue. "I believe the changeover to the new ICD-10 system is ultimately going to force healthcare systems and ASCs that have not already done so to go electronic," says Dr. Hauser. "The software can assist you when you get into this level of complexity and detail."

5. Dual coding preparation. The ICD-10 switch is only mandated for HIPAA-covered entities. Payers such as Worker's Compensation are not required to adopt ICD-10. "It will be important for everyone to realize they will likely need to utilize ICD-9 codes for some payers," says Ms. Hicks. "It is important they ensure they can dual code."

6. Testing. A successful switch not only hinges on an ASC's internal preparations, but also on all its trading partners. "ASCs will want to test with their clearinghouse partners, as well as coordinate with any third party solutions they may utilize to mitigate risk when the actual implementation does occur," says Ms. Hicks. The additional time also allows for testing with payers to gauge their level of preparedness and expectations.

Deadline dilemma
Oct. 1, 2014 was the concrete deadline for ICD-10, but it did not remain so. Could providers be expecting another reprieve and will this affect their preparation efforts? "Since this delay was introduced through the legislative process and not organized by CMS it is hard to know," says Ms. Hicks. The extra time for preparation is welcome for providers, but it is only a boon if thought of as a finite extension.

"At this point, I would be surprised if the deadline was ever moved again," says Dr. Hauser. "Essentially, plan on the new deadline as non-negotiable."

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