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HIMSS Responds to CMS Draft Regulations on ICD-10 and 5010

HIMSS has submitted a response to the Centers for Medicare and Medicaid Services call for comments on draft regulations for ICD-10 and the 5010 standard.  HIMSS’ response stresses the importance of moving forward with ICD-10 and the 5010 standard, and emphasizes the need for sufficient time to achieve compliance. To allow stakeholders adequate time to prepare and complete work efforts on the requirements, HIMSS calls for a minimum of two years between compliance dates.  

There are several key reasons for this position:

1. Compliance timeline challenging: The 18-month interval between the proposed 5010 compliance date of April 1, 2010 for 5010 and the proposed ICD-10 compliance date of October 1, 2011 is not adequate for successful implementation of 5010. Eighteen months would not allow enough time for implementation and testing of 5010 across all stakeholders to ensure interoperability and successful transaction processing of the new code set.   
2. Single Target Date Challenges: The industry has demonstrated difficulty with voluntary compliance towards a single target date while implementing previous HIPAA regulations. Adequate time is required for industry stakeholders to work in synchronizing efforts to achieve compliance of these two rules. If the industry does not make a coordinated approach to this single goal, the cost of achievement is escalated.
3. Workload Challenges: The combined transitions to 5010 and ICD-10 represent a significant workload for all stakeholders. The ICD-10 implementation will have a broad-reaching industry impact ranging from software systems updates to changes in workflow, business rules, operations and procedures.  Both 5010 and ICD-10 represent two distinct and significant software upgrades for vendors and provider end-users over the proposed three-year period.  

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HIMSS Virtual Conference Kicks Off Tomorrow

The fourth HIMSS Virtual Conference & Expo, kicking off tomorrow and running through Thursday, is the forum for growing professionally, researching technology solutions and connecting with peers online. Complimentary to qualified registrants,* the HIMSS Virtual Conference & Expo educational program includes opening and closing keynote sessions, education sessions around IT leadership, clinical informatics, ambulatory information systems and financial systems. Financial systems sessions will explore the latest drivers in healthcare revenue cycle management and examine how to leverage technology and enhance revenue through healthcare IT adoption.

In addition, attendees interact with speakers in live Q&A sessions after their presentations, as well as with peers and exhibitors in real time via threaded discussion boards in virtual lounges, or by using the internal instant messenger and e-mail systems. The virtual exhibit hall brings together attendees and leading industry vendors to easily explore cutting-edge product solutions through video demonstrations, downloadable product brochures and documents, as well as live chat. Plus, if registrants miss part of the live event, they can access all education sessions, keynote speeches and exhibits on demand for 30 days after conference.

Register for the HIMSS Virtual Conference & Expo.

*Registration is complimentary to qualified registrants: Non-qualified individuals may attend for a nominal fee ($79 HIMSS Members/$99 non-members).

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Report Studies Financial Impact of Consumer-Driven Health Plans on Providers

A report recently released by Cincinnati-based First Third Bank examining the expansion of Consumer Directed Healthcare (CDH) indicated that while most providers are beginning to feel the impact from CDH, few have adopted CDH specific “tools.”

Consumers are facing an increasing financial burden, with higher co-pays and deductibles. Repercussions from this shift are being felt by many key healthcare stakeholders, including providers, payors, employers and third-party service organizations. CDH is also expanding banks’ roles in offering services to the healthcare community.

“We were hearing from our customers—from physicians’ practices to hospitals—about the revenue cycle challenges they’re facing, but we didn’t see much data noting the impact of CDH from the provider perspective,” says Nav Ranajee, vice president, healthcare solutions at Fifth Third Bank. “Through this research , we wanted to better understand our customers’ challenges related to CDH, which will lead to the development of value added services." 

The study explored how providers are handling increased patient financial responsibilities and how this payment shift impacts a practice’s bottom-line. The study also examined provider offices’ front-end processes and best practices. Are providers making changes based on the impact of CDH?  Among the survey’s key findings:

• While new vendors are emerging to deliver technologies to assist providers with CDH challenges, providers are restrained by limited IT budgets and prefer fully-integrated CDH functionality provided by a single vendor.
• Patients don’t understand their high deductible health plans; neither health plans nor employers effectively communicate the financial responsibilities to consumers.

Mr. Ranajee reports survey results also found a disparity on the impact of CDH across the nation. “Providers practicing in certain areas of the country felt a much great er  impact from CDH than providers in other parts of the country, but part of the explanation for the disparity could be the lack of reporting or tracking by some providers on self-pay related to HDHP,” he says.

For providers starting to think about strategies for adapting to CDH, Mr. Ranajee notes that re-engineering front-end processes for payment collection is key. “Providers can utilize pre-registration services to remind patients about their appointment and note the amount they’ll be expected to pay,” he suggests. “Providers should also offer more payment options to patients—such as cash, checks, credit /debit, online bill pay, patient payment plans and patient financing. These strategies can improve payment collection rates.”

Research for the survey was conducted by Boundary Information Group, a consulting and research firm in Denver. The group interviewed healthcare executives and industry thought-leaders representing the nation’s hospitals and physicians.

Click here for more information on the survey or contact Mr. Ranajee at nav.ranajee@53.com.

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ICD–10 Conversion Planning Ahead Webinar

Wednesday, Dec. 3, 11 am – 12:30 pm Eastern

It is not too early to start planning for ICD-10.  Successful ICD-10 conversion will require a significant industry effort by all stakeholders.

This free Webinar, open to all HIMSS Chapters and HIMSS members, is a great opportunity to begin engaging in this important dialogue. The Webinar will explore how one organization's IT Department is preparing to support their organization through the ICD-10 transition.

Guest Speakers:      

• Philip Bradley, Vice President, Information Systems, Harris County Hospital District - HIMSS Financial Systems Steering Committee Member
• Mark Rich, Director PM/PA, Harris County Hospital District
• Allen Isaacson, IT Systems Architect, Harris County Hospital District

Register for this Webinar through Webex.

Individuals with questions about the Webinar can contact Holly Gaebel, coordinator, healthcare information systems.

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HIMSS Seeks Volunteers for Two New Financial Systems Work Groups

HIMSS is looking for volunteers to participate in the new financial systems work groups:

• Financial Systems Revenue Cycle Management Ambulatory Work Group—This new work group will leverage the Financial Systems Revenue Cycle Task Force White Paper Re-engineering the Revenue Cycle for the Emerging Medical Consumer, in developing a resource relevant to the ambulatory environment. Areas of focus for this work group include leveraging information technology with eligibility verification, denial process management, accounts receivable management and revenue cycle management. The deliverable of this work group will be an ambulatory addendum to the original white paper. The work group call will be the last Wednesday of each month at 11 am EST.
• Financial Systems and Quality Joint Work Group—This collaborative work group between the financial systems and patient safety and quality content areas, focuses around quality and price reporting. Efforts include an environmental scan of key quality/price reporting initiatives, identification of how healthcare IT is currently leveraged with these initiatives and review of future opportunities to leverage healthcare IT with these types of efforts. The results of this work group’s effort will be highlighted in a roundtable presentation at HIMSS09. This work group’s call will be the 2nd Thursday of each month at 1 pm EST.

Individuals interested in joining these work groups can contact Holly Gaebel, coordinator, healthcare information systems.

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Viewpoint: Risk Analysis—The Impact of Adopting and Implementing ICD-10 and 5010 Code Sets

In August, HHS announced proposed regulations to replace the ICD-9-CM code sets now used to report healthcare diagnoses and procedures with greatly expanded ICD-10 code sets, effective Oct. 1, 2011. In a separate proposed regulation, HHS has proposed adopting the updated X12 standard, Version 5010, and the National Council for Prescription Drug Programs standard, Version D.0, for electronic transactions, such as healthcare claims.  Click here for the full report on both proposed rules.

We posed the following questions to a few of our stakeholders: What do you anticipate to be the major area of impact in adopting and implementing ICD-10 and 5010 within your organization? Will your software vendors include these upgrades as part of their annual software upgrade, or will either one of these compliance efforts require expense above and beyond your anticipated support fees? Is all or part of these two efforts addressed within the “federal and state” clauses in your software contracts?  Here is what they are saying:

In August, HHS proposed rules to implement the revised HIPAA 5010 transaction sets and the ICD-10 diagnosis and procedure code sets by April 2010 and October 2011, respectively. If history is any indicator then IT vendors will need to modify their software to concurrently support the upgraded versions and the versions they are superceding for a prolonged period of time. Supporting 5010, 4010, ICD-10 and ICD-9 simultaneously is a huge undertaking that will drive up costs for hospitals, physicians and insurers. Once the industry picks dates for migrating to 5010 and ICD-10, use of the previous versions should not be permitted. HHS must enforce compliance and penalize violators to ensure the healthcare system reaps the efficiencies associated with standardization. That’s the lesson learned from the current situation under which some payors still require providers to submit both the legacy and new National Provider Identifier even though the law required providers to use only the latter effective May 23, 2008.

— John Hawkins, Senior Product Manager, QuadraMed

Expected Impact of 5010 and ICD-10 Code Sets
Vendors will work with payors to be compliant with 5010 transactions, whether to map the data to their current systems or help remediate those systems. But, there will be impacts to their business operations as a result of how the data is utilized. In particular, business operations that rely on this data will find significantly more detail in the 5010 transactions.

5010 represents “lessons learned” from 4010A1 implementation, as well as the addition of functionality to accommodate changes in healthcare transactional requirements since 2002. These changes represent clarity and consistency in defining the business processes around transaction usage. Potential 5010 impacts will involve updates required to accommodate updated syntax for all transaction types. A major issue will be how payors and providers continue operations at different stages of compliance on April 1, 2010.

Overall, ICD-10 will enable significant changes to codes used for diagnoses and inpatient hospital procedures. ICD-9 codes in use over 25 years do not reflect today’s technology and practice of medicine. Consequently, ICD-10 code sets to be implemented Oct. 1, 2011, will provide more healthcare detail for classification purposes. Industry-wide, the increased personal data in ICD-10 codes will trigger: payor adjudication system changes, modifications to edits, statistical analysis and capitation system as well as privacy and security implications.

— Frank O’Roark, Vice President, Payor Services, RelayHealth

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Advocacy Updates

2008 Election Results and Implications for Health IT
As this exciting election year comes to a close, U.S. Senator Barack Obama (D-IL) has been elected as the 44th president and Democrats have retained a majority in the U.S. Congress. As a bi-partisan issue among members of Congress, health information technology will continue to play a leading role in policy to transform the delivery of healthcare in the United States. HIMSS has released an article offering insights into the election results with key highlights and implications for 2009. The article explores results from the Presidential race, Congressional races and State Legislative races, in addition to noting where health IT legislation may be headed in the 2009 and with the new administration.

Presidential Campaigns Highlight Health IT Public Policy Forum
“Health IT Priorities in the New Political Landscape” was the focus of HIMSS’ 6th Annual Public Policy Forum at the National Press Club on October 28. Top health policy advisors for both Presidential candidates debated health IT issues and responded to questions about the candidates’ stances on health IT and how each planned to address the issue. The healthcare challenges that will face the new president were presented by Roll Call Executive Editor Morton Kondracke in his closing keynote address, The 2008 Presidential Election and the future of Health Information Technology Policy. 

Among the forum’s presentations, a panel discussion explored the possible impact of a new political landscape on clinicians and payment reform. Miriam Paramore, chair of HIMSS’ Financial Systems Steering Committee and senior vice president of corporate strategy, Emdeon, participated in the panel, offering the health IT industry perspective. Also during the Public Policy Forum, HIMSS released its inaugural HIMSS Security Survey, which surveyed senior healthcare executives on safeguards regarding the use of IT. The survey found that the majority of healthcare organizations have taken steps in the past year to increase the security of patient data, though just 20 percent of respondents reported data breaches.

Audio recordings of presentations from the Public Policy Forum are available online.

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