Five risk management focus areas for ICD-10’s home stretch: Creating and maintaining conditions for success

Michael RoachFred DiLuzioHealthcare institutions impacted by ICD-10 are nearing the end of their multi-year journey, but despite intensive preparation efforts they may still face a number of challenges. Primary among these challenges are keeping the organization focused and finishing the tasks required to achieve a successful ICD-10 conversion on Oct. 1, 2015. Enterprise risk management between during this “home stretch” is essential to ensure our institutions are prepared for success.

The following five enterprise risk management focus areas require even more concentrated attention as we enter these final months:

  1. Sustainability. Sustain your ICD-10 team’s engagement. In these final months your stakeholder’s attention can shift to newer, “fresher” initiatives (BSOS, or “Bright Shiny Object Syndrome”). If this occurs, remind your stakeholders what’s at stake should your organization fail to be fully prepared.  Consider incentives for key project members that can include project bonuses and/or the opportunity for other prized assignments conditional on successful completion. Some turnover and natural attrition are common to long projects; however, maintaining ICD-10 expertise and longitudinal knowledge through the post implementation warranty period is one of your critical conditions for success.
  2. Engagement. Reach out regularly and in person to your key stakeholders and their teams to ensure they remain focused on assigned tasks and on their specific preparations for ICD-10 readiness.  These engagements are separate from project meetings and steering committee reviews, and often uncover important ICD-10 issues and concerns that can be overlooked and overshadowed in other forums.
  3. Connection. Increase the frequency of ongoing payer-provider communications to ensure ICD-10 readiness on both sides. Your risk focus will likely be on mitigating smaller payers and/or clearing houses that may not have yet demonstrated full readiness to receive ICD-10 claims. In these cases, consider as a condition of success a pre-cutover agreement to contractually require a specific percentage payment pending resolution of claims status within a specified date range (i.e. six months).
  4. Practice. Maintain your enterprise’s focus on potential revenue and cash flow impacts by engaging stakeholders in mock scenarios to simulate ICD-10 issues such as increased A/R days or a high rate of claims denials by a specific payer (or combination of payers). These exercises will help establish practiced responses to anticipated issues so the organization can knowingly and quickly react as needed. These practice drills are best led by your business leaders, not the core project team, and create conditions for success by building in contingent responses based on real business scenarios. In addition, this further prepares business stakeholders to assume control of the ICD-10 program after the dust settles on what will most likely be minimal issues associated with already tested and remediated revenue cycle, business, and clinical applications.
  5. Bonding. Identify contacts and their information (specific names and phone numbers) from all external business partners who may need to be contacted for issues remediation starting Oct. 1. Include all payers, vendors, clearing houses, etc., whose scope includes ICD-10 payments and data transfers with your organization. Confirm and document each partner’s own ICD-10 support process and escalation path in advance.

It looks near certain ICD-10 is on course for an Oct. 1, 2015 cutover with the recent joint announcement by CMS and the AMA to provide more flexibility and support during post implementation. Your organization’s “home stretch” enterprise risk management must embrace the same focus we apply to other large-scale, cross-functional, multi-year initiatives where deliberate and proactive preparations are essential requirements to create the conditions for success.

Fred DiLuzio is the ICD-10 Program Manager for Hoag Memorial Hospital Presbyterian and has had oversight for this initiative since 2011. Fred has over 20 years’ experience in health care, with leadership roles in both hospital systems and managed care.

Michael Roach has led highly recognized Program Management Offices for over three decades, with ten years’ experience in healthcare and biotechnology. Michael has held senior roles in technological advancements, business development, mergers and acquisitions, and has portfolio-level accountability for ICD-10 at Hoag Memorial Hospital Presbyterian.