ICD-10 implementations are shifting.  The center of gravity is slowly moving from predominantly payer centric industry activity to provider centric as more hospital systems close in on achieving meaningful use of electronic medical records.   Many hospitals might assume that their EMR vendor will make them ICD-10 compliant.  However as we were reminded in a recent conversation with a large hospital system, most have hundreds of systems that will be impacted by ICD-10.  Electronic medical records are one important system of record for ICD-10 diagnosis and procedure codes, however there are many more.     We recommend that HIPAA Covered Entities think holistically about the ICD-10 effort and realize that the EMR vendor may address what’s in their solution, but they cannot remediate your internal, custom systems or legacy systems, processes, etc.

Once the remediation effort begins, the need for robust  integration capabilities between systems becomes more important.  HIT vendors tend to focus on integration among their product line, and do not provide the mature enterprise messaging capabilities found in leading enterprise software vendor product lines.

Look for a balanced approach between EMR vendor, other systems, and an integration strategy that is vendor neutral, enabling all impacted systems to work together to assist in the ICD-10 transition.

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The Health Information Technology for Economic and Clinical Health (HITECH) Act – part of the Patient Protection and Affordable Care Act (PPACA) – provides incentives for the adoption of electronic medical records (EMRs) and related technologies.  The Centers for Medicare and Medicaid (CMS) mandated change to a new HIPAA diagnosis and procedure coding standard, ICD-10 by October 1, 2013.  Many don’t yet see the inter-relationship between between EMRs and ICD-10.  Without coordination between EMR and ICD-10 the clinical documentation of medical necessity that determines claims payment, hospital revenue cycles will be at risk, because the EMR is a container for the ICD-10 codes.  And, most health care companies have hundreds of systems that will be impacted by ICD-10.  Some hospitals run on a 2% profit margin.  Payment reform incentives and penalties based on quality measures – reported in the future using ICD-10 – present unprecedented risk and opportunity to this margin.  A one percent shift in revenue cycle management (RCM) reimbursements is worth $2.6 Billion to our health care economy.

Yet today we find that 35% on average of an organization’s current EMR,  supporting analytics, RCM, documentation and processes will not have the specificity for the new ICD-10 code sets.

This means hospital billing and reimbursements, claims auto adjudication rates, and other health care metrics stand to be negatively impacted.  Meaningful use (MU) of EMRs is an exercise in language.  It translates the vocabulary that physicians use into codes – like ICD-10.  Furthermore, the supporting analytics aren’t tuned to report on ICD-10 CM and ICD-10 PCS (CM for diagnosis and PCS procedure) codes.

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