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US Financial Impact of ICD 10 On Hospitals
US Financial Impact of ICD 10 On Hospitals
Produced by the
Deloitte Center
for Health Solutions
Updated Summer 2009
based on HHS Final Rule CMS-0013-F
ICD-10
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for a detailed description of the legal structure of Deloitte LLP and its subsidiaries.
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ICD-10
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ICD-10
Corresponding
ICD–10 & Provider Trends
Health Advocacy
Subtantial capital investment & modernization efforts launched
3
ICD–10 &
Consolidation to
Consumer-
Uniform Systems
Centric Model
Rollup of small health plans and providers Platform
2
Patient-Centric
Initial Consolidation HIPAA & Capabilities
1 Y2K
Y2K &
Managed Emergence
Care of the EMR
Best-of-Breed
Automation Time Frame
ICD-10, combined with other trends, will drive another spending wave,
which will lead to consolidation pressure with both providers and payors
As illustrated above, managed care initiated a major wave of IT remediate their large legacy applications to accommodate a
investment for payors, with many considering consolidation to 4-digit-year field. While providers were dealing with similar
scale their operating and technology models. Simultaneously, concerns, this period also saw an aggressive move toward
providers were installing and attempting to integrate myriad implementation of electronic medical records (EMRs), which
package applications across their front and back offices and had finally matured to a point where viable solutions existed
ancillary service areas. Compliance with the 1996 Health which had both state-of-the-art functionality and a reasonable
Information Portability and Accountability Act (HIPAA) and price tag. These first two waves of investment were major
measures to address Year 2000 (Y2K) concerns initiated contributors to the massive complexity and associated
the second wave of IT investment, forcing health plans to operating costs of today’s IT systems.
standardize their interactions with outside constituents and
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ICD-10
What is ICD-10?
When a physician evaluates a patient, the physician collects
subjective and objective data (the “history and physical”)
to diagnose the patient’s condition and develop a plan for
treatment. The most widely used diagnostic taxonomy in health
care is the World Health Organization’s International Statistical
Classification of Diseases and Related Health Problems (ICD).3
The ICD is a coding of diseases and signs, symptoms, abnormal
findings, complaints, social circumstances and external causes of
injury or diseases4 that is used internationally to classify morbidity
and mortality data for vital health statistics tracking and in the
U.S. for health insurance claim reimbursement.
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ICD-10
Germany
United Kingdom • Adopted in 1998
Canada • Adopted in 1995 • ICD–10–AM for morbidity
• Began adopting in 2001 • Implementation took 3 years
• Over 5-year
implementation
• ICD–10–CA for morbidity Russia
• Coding is used for
• Adopted in 1999
statistical purposes
rather than for billing
China
• Adopted in 2002
Australia
Brazil
France • Adopted in 1998
• Adopted in 1998 • Implementation took 2 years
• Adopted in 1996
• 2 years from decision
to change to actual
implementation was
insufficient lead time
to build the classification
South Africa and educate users
• Adopted in 1996
SOURCE: http://www.who.int/classifications/icd/en/
ICD-10 Could Eclipse Y2K re-mapping interfaces and recreating reports/extracts used by
all constituents who access diagnosis codes. In short, ICD-
in Scope and Complexity 10 implementation has the potential to be so invasive that
U.S. adoption of ICD-10 will undoubtedly require a massive it could touch nearly all operational systems and procedures
overhaul of the nation’s medical coding system because the of the core payor administration process and the provider
current ICD-9 codes are deeply imbedded as part of the revenue cycle.
coding, reporting and reimbursement analysis performed
today. Indeed, ICD-10 implementation has the potential to Clearly, U.S. health care organizations have much to consider
overtake Y2K in terms of impact and cost. It will require a before deciding how to address ICD-10 compliance. The Deloitte
massive wave of system reviews, new medical coding or Center for Health Solutions encourages those payors and
extensive updates to existing software, and changes to many providers who are seeking long-term viability to consider ICD-10’s
system interfaces. Because of the complex structure of ICD- impact to their overall strategic plan before choosing an adoption
10 codes, implementing and testing the changes in EMRs, strategy. While ICD-10 might at first appear to be solely a tactical
billing systems, reporting packages, decision and analytical remediation effort, we view ICD-10 as a potential platform for
systems will require more effort than simply testing data future strategic innovation.
fields – it will involve installing new code sets, training coders,
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ICD-10
Where Does U.S. ICD-10 been a concerted effort to determine the ruling’s impact on
core operations and infrastructure; numerous health plans have
Implementation Stand Today? been conducting assessments and developing remediation
Since final publication in January 2009 of the HHS rulings for both plans. This activity is understandable and warranted, given
Version 5010 of the X12 Standard and ICD-10, there has been a the potential breadth and depth of ICD-10’s impact on health
significant increase in activities around adoption and compliance. plan administrative operations: Assessments that Deloitte has
The 5010 mandate is the higher priority because its testing and conducted at several commercial health plans have determined
compliance dates are more near-term (January 2011 for testing that the combined net effect of the 5010 and ICD-10 rulings
and 2012 for compliance). As of mid-2009, most covered entities could impact 70-80 percent of a health plan’s business processes
are either implementing a 5010 impact assessment and associated and systems.6 Also, unlike previous HIPAA regulations, the
planning or are preparing to do so. Some organizations intend to 5010/ICD-10 impact extends to technology and infrastructure
be fully compliant by the 2011 testing date. investments, core business processes and training for staff
responsibilities across multiple functions. Figure 3 illustrates the
Reactions to ICD-10 across the covered entities have been potential impact on a health plan’s claims adjudication process.
mixed. In the health plan community, for example, there has
Update
electronic
Select systems to
Provider Begin claim accept claims
Determine adjudication
Benefit process
Levels Check
Eligibility
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ICD-10
Health plans also want more education and information on 5010 Medical Association (AMA) and American Hospital Association
and ICD-10 from their industry trade groups and associations. (AHA) have been providing educational and technical support,
In response, organizations such as America’s Health Insurance but providers seem to be focusing primarily on health reform
Plans (AHIP) are developing programs to provide insight and and potential Medicare cuts. However, there is little doubt that
information to their member communities. provider core operations also will be dramatically impacted by
ICD-10, as illustrated in Figure 4.
Among health care providers, the sense of urgency around
ICD-10 preparedness has not been as evident as it has for
health plans. Leading industry groups such as the American
Charge
Process
Patient Access Department Nursing Med Records Finance Patient Accounting Department
Function
Information Systems
Regulatory Compliance
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ICD-10
Value Competitive
Negative ROI Break – Even
Realization Advantage
Benefit
CMS- Cost
Strategic Value
Mandated
Changes
• Basic Coding • Core Administrative • Remediation of • Advanced Analytics • Transformed HCM, Contracting,
• EDI Transactions & Revenue Cycle Internal Reporting • Payment Monitoring & Business Acquisition
• Government Reporting Processes • Advanced Training, Outcomes
Mgmt, & Physician Score Cards
Integration Level
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ICD-10
Pragmatists
We expect that nearly 60 percent of all health care entities will
achieve basic ICD-10 compliance – the bare minimum required
by law. This means they will be investing only in infrastructure to
fulfill core CMS mandates: claims adjudication, referral processing
and related communication of health transactions for payors; and
basic coding and core revenue cycle processing using the ICD-10
code set for providers. We expect that organizations which choose
this approach will look to leverage “wrap-around” solutions such
as EDI crosswalks and similar technologies that attempt to shield
core processes and systems from the invasive nature of the ICD-10
mandate. However, lessons learned from HIPAA and NPI have
shown that organizations often underestimate the complexity of
these solutions, which ultimately bear very large costs but yield
very little strategic value.
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ICD-10
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ICD-10
• Personal Health Records Opportunities – Using ICD-10 codes, Step 1: Identify your organization’s position along
innovative health care entities will have access to information the ICD-10 remediation spectrum – Every health care
at a level of detail never before available, making regional organization should proactively decide how it will deal with
and personal health records (PHRs) more achievable for ICD-10. Do you want to be a pragmatist, a collaborator,
the provider and member communities. Organizations that or an innovator? Each of these positions carries trade-offs
align themselves appropriately can provide a service that will with respect to cost, solution quality and market position.
differentiate them in the marketplace. This decision requires a thoughtful review of your corporate
strategy and whether ICD-10 can be leveraged to support
• Clinical Documentation Excellence Program – Developing other corporate goals.
and implementing a Clinical Documentation Excellence (CDE)
program is a critical component of organizational preparedness Step 2: Begin assessing impacts – Your organization should
to respond to future regulatory changes. Hospitals need to complete a high-level impact assessment to determine the
understand the financial impact that ICD-10 will have on their potential size and scope of basic remediation. Determining
bottom line and begin the operational readiness assessments, how much the current ICD-9 code set is ingrained in your
gap analyses and process improvement plans to facilitate organization’s operations and technology infrastructure will be
accurate and appropriate reimbursement. a key indication of how invasive the transformation could be.
Similarly, if your organization wants to be an innovator, it is
• Opportunities to Leverage Non-Traditional Staffing Models important to begin identifying and planning for the significant
– Providers have experienced stress from the national changes that will be required to support new business models
shortage of professional certified coders for many years. and the associated technical and organizational adaptations.
Coding changes such as CMS’ Medical Severity Diagnosis
Related Groups (MS-DRGs) are exacerbating this shortage by Step 3 (optional): Identify collaborators – If your
reducing inpatient coding productivity. Most providers are organization deems itself a collaborator or innovator, it is
augmenting coding staff to mitigate increased receivables prudent to understand how collaboration might be achieved,
during the learning curve. Providers that opt to pursue non- and to identify potential targets in the marketplace. Because
traditional staffing models for professional coders, such as partnering arrangements between organizations often require
home-coding programs, will be better positioned to respond lengthy negotiation and legal proceedings, it is important to
to the continued coding shortages – including ICD-10 – and begin this process early to meet important goals and milestones.
not be limited by geography.
The road to ICD-10 compliance will be neither easy nor quick.
While the potential benefits of being an ICD-10 innovator are However, with foresight and planning, health care providers
great, it is clear that achieving them will require significant capital and payors can transform a regulatory necessity into a
and personnel investments. Those organizations that are genuinely competitive advantage.
interested in leveraging ICD-10 for competitive advantage should
align their ICD-10 remediation strategy, approach and roadmap
with other key long-term corporate initiatives. A program of this
magnitude runs the risk of wavering support and sponsorship if it
encounters implementation difficulties; however, securing up-front
executive alignment can help to mitigate these challenges.
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ICD-10
Authors Contributors
We’d like to recognize the individuals who This paper is a result of a team effort that spanned our
contributed their insights and support to this project. Health Sciences and Government industry practices. Casey
Graves, Senior Manager, Deloitte Consulting LLP, and
David Biel Heather McPherson, Senior Manager, Deloitte Consulting
Principal LLP provided content input. Erin Poetter, National
Deloitte Consulting LLP Marketing, Deloitte Services LP, helped with publication
dbiel@deloitte.com and marketing activities.
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About the Center
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located in Washington, D.C., is part of Deloitte LLP and
was formed to further research and develop insights on
some of our nation’s most pressing health care and public
health-related challenges.
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