The healthcare industry was shocked by another delay of ICD-10. After two previous delays, most healthcare stakeholders, especially health insurers, were operating at full steam to ensure that compliance date of 2014. Now the challenge is making sure all that work wasn't for naught.
Fifteen days after the law was enacted, CMC finally broke the silence with a simple statement posted on the website promising guidance for stakeholders soon.
An unexpected delay at this juncture of the compliance journey has significant implications for health insurers, providers, PBMs and others, regardless of where they are in terms of ICD-10 compliance. One more year of ICD-10 implementation delay is expected to cost between $1 billion to $6 billion for the healthcare industry.
Large payers have been investing profoundly to meet the compliance, and many changed their business and technology strategies accordingly. Even many of the midsize and small payers postponed other healthcare initiatives and allocated more in their budgets to meet ICD-10 compliance for the 2014 mandate. For them another delay may be a frustrating moment.
Now, they have to save what has be achieved so far and identify additional scope of work, stop testing what is not required, utilize time available to deep-dive critical areas for testing, expand external trading partner testing, and retain knowledge gained so far.
Save early progress
Payers should conduct quick test assessment focusing on identifying needed in 2015 and determine what has been already remediated and tested from that portion. Payers also need to identify systems which are not part of the 2014 IT landscape and will be added in 2015. These systems need to be analyzed for possible ICD-10 impact, remediated and tested with traditional and non-traditional testing types to ensure that they are capable of handling ICD-10 codes as part of 2015 application landscape.
For example, payers may have adopted crosswalk remediation approach for legacy claim systems which might have been planned to sun set by 2015. Testing of such systems can be stopped immediately. This will help to avoid unwanted testing efforts.
Some of the lagging testing activities might have been re-planned with reduced, suboptimal or compromised efforts in order to meet 2014 timelines for few or many critical impacted areas. Given the additional time available for ICD-10 implementation now, payers can revisit progress of critical impacted areas including EDI, claims processing, utilization management, care management, and underwriting. These areas should be reassessed and optimized for testing in order to ensure smooth remediation of these impacted areas.
Expand scope of external trading partner testing
Demand trading partner testing may increase due to the extension of the timeframe. Payers can use additional time available and invest in trading partner testing to remove the uncertainty of smooth transition post go-live. This will require more collaboration and alignment for re-planning, designing and test execution. Initial time constrain forced payers to shrink the test coverage and adopt prioritization approach for coverage.
Payers now have the opportunity to expand the scope of testing. For example, they should not allow a single provider to increase large numbers of claims for similar patient conditions. Providers would be able to identify codes which reimburse the maximum amount for particular patient condition. Instead, payers should increase the number of providers and claims with different patient conditions focusing on clinical aspects. This will expand the scope of clinical condition and avoid showing codes that are more profitable to them.
Retain knowledge gained so far for various testing activities
Retaining knowledge is one of the major issues which most of the payers are required to plan, especially those who are already prepared for the 2014 compliance date. For them, retaining knowledgeable testing resources for next year or allocating them in other programs is a difficult decision. There is a high possibility that the delay will result in a loss of momentum or may lead them off the track for some time. It is important to retain critical resources or allocate them in the short-term so that they can be brought back to ICD-10 testing once it picks up, per a revised test plan. Before allocating critical resources to different programs, it is important to make sure the knowledge is being well documented and required re-training programs are being planned which can help to bring back the momentum.
Though it is frustrating for many payers who are already ready for 2014 compliance, it is important for them to conduct test assessments to evaluate current positions and realign all testing activities to suit 2015 compliance. This delay will certainly have heat on their budget for testing activities; however they have another opportunity to expand scope of areas where inadequate testing is being. Small payers running behind schedule should correct their problems now given that there is sufficient time available.
Anuj Shah is a solutions manager at Cognizant Technology.