Compliance Auditors Needed for Successful ICD-10 Migration

“How many of you have tried to change physician behavior…or anyone’s, for that matter?” asked a panelist. The crowd chuckled.

At the recent NE Regional HCCA conference in Boston, Hayes’ MDaudit Director, Robert Freedman, led a panel discussion about ICD-10 and its impact on billing compliance. Panelists included Cynthia Trapp, Director of Professional Coding at Lahey Clinic; Patrice DeVoe, Director of ICD-10 and Infrastructure Initiatives at Tufts Health Plan, and Linda Howrey, JD, Principal Compliance Consultant at Hayes.

Robert Freedman moderated the panel

The panel focused on physician documentation. “ICD-10’s increased specificity demands more detailed documentation,” said Howrey. “If the documentation is insufficient, the charge will be rejected, delaying reimbursement. If an ICD-10 code cannot be found for the charge and it is coded as ‘unspecified’, it can be denied. This is very different than ICD-9.”

“Physicians will need to change the way they do everything – down to dictation,” said Trapp. “A habit done the same way for years is hard to change.”

Panelists urged participants to start educating familiarizing physicians with ICD-10 now. “We can’t wait until 2013, get all the clinicians in a room and teach them,” said DeVoe.”

HCCA panelists from left to right: Cynthia Trapp, Robert Freedman, Linda Howrey, Patrice DeVoe

When Freedman asked the attendees if any of their organizations have begun physician education on ICD-10, no hands were raised. “I’m not surprised,” shared a clinical documentation specialist after the meeting. “People don’t see the urgency – they are just going to wait until the last minute and it’s going to be a fire drill.”

The panelists’ organizations, however, are ahead of this curve. DeVoe went into detail about Tufts’ planning, which started a year ago. “We are reserving a year just for testing,” she said. Lahey is adopting a train-the-trainer approach, certifying an experienced coder to train other coders. To educate physicians, Lahey’s physician coders are adding ICD-10 criteria to their internal physician audits.

“Regardless of the internal audit results, we have a one-on-one meeting with physicians to show them how their current documentation compares to what will be needed for ICD-10, and we ask them what they would do to meet the ICD-10 requirements,” said Trapp. “This has been very well received.

Many participants reported that the medical records department was responsible for training on ICD-10. Linda Howrey says this is common, but foresees a problem with this model. “Medical records’ staff works closely with the EMR team, but the EMR is not going to solve all the ICD-10 issues. Compliance professionals are intimately familiar with coding and with the risk associated with incorrect coding and insufficient documentation. Silos are forming, and it’s unfortunate. This is an enterprise-wide change, and should be an enterprise-wide effort.”

However, compliance departments have resource constraints. Furthermore, coders need to be educated as well – many need refresher training on anatomy & physiology. How can this huge training need be met with scarce resources?

Panelists gave the following tips:

• If you are working in an academic medical center, look for an anatomy & physiology course on campus for your coders - or see what is offered close to your facility.
• Send experienced coders to obtain an ICD-10 train-the-trainer certification at AAPC or AHIMA, and have them train the other coders.
• Add the ICD-10 component to your internal audits as Lahey is doing

“The change is going to be much bigger than Y2K,” said Trapp. “The key is to help our organizations stabilize through the transition to reduce risk and revenue loss. The time to start training physicians is now.”

It was clear at the end of this session that compliance auditor’s knowledge and relationship to physicians is a valuable asset that should be leveraged so that documentation is sufficient on October 1, 2013.