How Should Medicaids Respond to the ICD-10 Postponement?

State Medicaid Agencies Face Challenges and Opportunities as Regulatory Mandates and Coverage

Expansions Converge

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How Should MEDICAIDS Respond to the ICD-10 PostponementOctober 2012

Contents

HOW SHOULD MEDICAIDS RESPOND TO THE ICD-10 POSTPONEMENT?.................................................1

MEDICAID CHALLENGES..................................................................................................................................1

WHAT CAN STATES DO WITH THE “EXTRA” YEAR...........................................................................................2

WHAT COGNOSANTE CAN DO FOR YOU..........................................................................................................2

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How Should MEDICAIDS Respond to the ICD-10 PostponementOctober 2012

HOW SHOULD MEDICAIDS RESPOND TO THE ICD-10 POSTPONEMENT?

State Medicaid Agencies Face Challenges and Opportunities as Regulatory Mandates and Coverage Expansions Converge

“HHS Secretary Kathleen Sebelius Announces Delay of ICD-10 until October 1, 2014” was the title of a CMS press release dated April 9, 2012. The news came in response to political pressures to postpone the original October 2013 deadline and ongoing industry concerns related to the bumpy transition to the new 5010 versions of electronic transactions.

An August 24 announcement made the one-year postponement official. The goalposts have been moved, but now they are firmly set in place.

Medicaid Challenges

While the ICD-10 mandate applies to all health care providers and health plans, public and private, the additional layers of budget constraints and the expansion of coverage add unique challenges to State Medicaid Agencies (SMAs) and the contractors who support them.

ICD-10 comes as a complicating – but necessary – addition to an environment also driven by:

Expansion of the covered patient population and the implementation of Health Information Exchanges (HIX) under the Affordable Care Act (ACA)

Federally-mandated initiatives such as Health Insurance Exchange (HIE), and Electronic Health Record (EHR) Incentive program under the American Reinvestment and Recovery Act (ARRA)

Updates to the Medicaid Information Technology Architecture (MITA) framework and “Seven Standards” Enhanced Funding Requirements

While federal funding is available for the various initiatives, dynamics between the federal and state government can complicate the financing picture as state budgets and human resources are strained in the current economy. Moreover, as much as the federal policies and programs arise from a common understanding of the cost and quality benefits of healthcare IT, the regulations and directives do not connect the dots. By necessity, the integration and coordination of the programs need to take place at the state level.

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How Should MEDICAIDS Respond to the ICD-10 PostponementOctober 2012

What Can States Do With the “Extra” Year

Following are three actions states can take to ensure the continuity of their ICD-10 transition efforts:

1. Continue efforts underway and allocate extra time for testing

While even the mention of a delay tends to impact forward momentum, SMAs should stay focused on efforts underway, heeding the advice of CMS and industry experts to allocate the additional time for testing. Some states are sticking to their original implementation schedule, planning for a full year of provider outreach and end-to-end testing

2. Pursue funding from CMS

State funding will remain constrained, but CMS has encouraged SMAs to continue to submit Advanced Planning Documents (APD) for review. Revisit prior plans and estimates to ensure you have resources in place for the longer haul.

3. Integrate rather than isolate

ICD-10 projects, and any downstream effects of the delay, should be re-assessed in light of other initiatives underway. New MMIS procurements, HIE, HIX and the enrollment of new beneficiaries under the ACA expansion may all be impacted by the timing of ICD-10, both in terms of data requirements and competition for scarce resources. Conventional impact analyses tends to proceed from the “as-is” state to a “to-be” state; however, with many systems being simultaneously developed and deployed, there must be an appreciation for how these multiple “yet to be” systems need to work together and how they will enhance value. Active outreach and coordination between stakeholders in the implementation efforts is key.

What Cognosante Can Do For You

Cognosante’s Standards Practice professionals have conducted and implemented full-scale ICD-10 remediation projects for SMAs and other health plans, both public and private. If you are starting late, we have the been there/done that expertise to help you get up to speed quickly. For SMAs who have already conducted an enterprise-wide ICD-10 impact assessment and are looking for support in the next phase of the process, Cognosante has trained and experienced staff ready to assist with the critical resources needed for a successful remediation effort.

Translation Services

The "bad news" of initial ICD-10 assessments is that there is no black box technical solution that allows you to pour ICD-9 codes in on one side and instantly retrieve equivalent ICD-10s out the other. The good news is that taking a hard look at medical policies, edits, audits and pre-auth rules can yield cost savings and service enhancements. Cognosante’s “policy first” translation services focus on using sophisticated tools to capture the meaning and clinical intent of your existing policies and business rules so they can be consistently interpreted in both ICD-9 and ICD-10.

Testing/Test Planning/Approach

Unlike prior transaction-based HIPAA mandates such as NPI and 5010/D.0, the ICD-10 mandate offers no "parallel processing" window. According to the rule, all dates of service (DOS) prior to the Compliance Date must be ICD-9 and only ICD-9; all DOS on or after the Compliance Date must be ICD-10 and only ICD-10. This industry-wide “Big Bang” implementation adds to the level of complexity and reinforces the importance of hands-on, end-to-end testing across the enterprise and with external trading partners. Cognosante’s industry savvy and testing services experience will help you plan, establish and implement a testing solution that verifies the use of the new codes, not just their length and format.

Provider Outreach

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How Should MEDICAIDS Respond to the ICD-10 PostponementOctober 2012

The detail that all health plans, public and private, must remember is that all their diagnosis and procedure data originates with providers - if providers don't capture it, health plans can't use it; if that capture process isn't accurate, the data won't be reliable. It's understood that there will be a transitional period during which both groups will become accommodated to working with the new coding systems, but that only adds to the importance of working together prior to the transition. Most Medicaid providers also serve patients covered by other health plans, such as Medicare, Blue Cross or commercial plans, who may be providing ICD-10 training and guidance. But other providers, who rely on Medicaid exclusively, may be looking to a particular SMA for virtually all of their ICD-10 guidance. Cognosante helps you leverage your existing communications resources to deliver timely, accurate, and consistent provider messaging for the ICD-10 transition.

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