Think your challenges are daunting when it comes to implementing ICD-10? Put things in perspective by imagining the Mount Everest the Centers for Medicare & Medicaid Services has to climb.
“Given the extent to which the code set is built into many business and operating processes and systems, the size of CMS operations, and the complexity of its systems,” the challenges CMS faces are formidable, says a report published last week from the National Research Council. The report was commissioned by CMS to help it better understand how to modernize its own information technology. It highlights the challenges CMS faces and some opportunities, too.
[See also: Survey analysis: The challenges of ICD-10.]
The NRC outlined CMS’ challenges as:
1. Distributed ownership and collaborative governance. CMS will have to coordinate an enterprise-wide effort of this size across multiple independent divisions, units, projects, and systems in a timely and coordinated manner.
2. Program and system interdependencies. CMS must coordinate the interdependencies between discrete projects affected by ICD-10 and crosscutting themes related to ICD-10 affecting multiple programs and units – for example, having an enterprise-wide crosswalk approach between ICD-9 and ICD-10.
3. Competing initiatives. In addition to ICD-10, CMS, and OESS specifically, is challenged with having to implement several other agency-wide initiatives and oversee national healthcare reform efforts that may detract from the ICD-10 transition.
Sound familiar? Almost every payer and provider faces that same heaping pile of changes, be they incentivized or merely unfunded mandates, namely HIPAA 5010 and ICD-10. Much like those other private and public health entities that must convert, ICD-10 also creates some opportunities for CMS.
NRC lists three of those as:
1. The chance to consider “phasing-out legacy systems” or functions, as CMS may find it more cost effective to implement new IT than to remediate or upgrade systems and applications simply to comply with ICD-10.
2. The ability to leverage ICD-10’s greater granularity “to establish more effective processes and perform and execute more refined controls in areas such as quality, patient safety, population health management, and fraud and abuse.” NRC noted that these improved capabilities may prove “particularly valuable” as the new accountable care organization model continues to expand.
3. The chance to use ICD-10 to form “more effective outcomes-based payment and reimbursement policies,” such as those under the Patient Protection and Affordable Care Act.