Today at the WEDI ICD-10 Forum in Fairfax Virginia, Robert L. Guenther, Technical Director for the U.S. Department of Health and Human Services at the Centers for  Medicare and Medicaid Services concluded that “All States are at high risk” in terms of their ability to complete CMS requirements at a state level to implement ICD-10.

The key issue will focus not on technical, IT oriented approaches but on leadership and a view of the real business issues around implementing ICD-10.

Iowa however is one of the few states that appears to be ahead of other states.  Iowa Medicaid Enteprise (IME) is successful due in part to the early realization by IME leadership that:

  • The largest impact will be to policy and business, not technical.
  • Deadlines are firm and will not be extended
  • Subject matter expertise will be important in making ICD-10 implementation a success.
  • Best practices include:

    • A collaborative environment
    • Complete operational procedure documents
    • Comprehensive systems documentation
    • IME completed a MITA State Self-Assessment (SS-A) completed in May 2009 which covers the 79 business processes that all states need to master and document which would have business, system and process impact.

    There is a business architecture that spans all operational functions.  In addition IME performed a gap analysis that helped guide them by using “high,” “medium,” and “low” as the impact rating system.

    They scored their strategies with benefits, drawbacks, costs, best use as well as the costs to implement.

    IME’s performance based model implies higher weights toward categories that influcence program integrity and quality:

    The high level estimated percentages for weighting were established which focused in context of ICD-9, ICD-10 and mapping both directions.  The benefits, drawbacks, and best use categories were considered.  The cost range for the State of Iowa was between $8 million and $10 million for a level of compliance that didn’t meet all requirements, an “intermediate” level of compliance would cost up to $11 million, and “optimal” compliance would cost $14.6 to $17.6 million.  This estimate is nearly twice the estimate of CMS for a state to implement ICD-10.

    Other IME considerations:

    Challenges with NPI translation approach

    • Project estimates are much larger than anticipated (2-3 times NPI [national provider id] project costs).  For most, NPI was a difficult and expensive task for health care companies.
    • Project impacts and recommendations need to be communicated effectively to the executive team
    • System replacement options and implications

    Our team would be happy to help develop your plans using our experience and best practices.  Contact us by email

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