ICD-10 Implementation – CMS Says “All States at High Risk”

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 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
    at [email protected].

    Michael F. Arrigo

    Michael is Managing Partner & CEO of No World Borders, a leading healthcare management and IT consulting firm. He serves as an expert witness in Federal and State Court and was recently ruled as an expert by a 9th Circuit Federal Judge. He serves as a patent expert witness on intellectual property disputes, both as a Technical Expert and a Damages expert. His vision for the firm is to continue acquisition of skills and technology that support the intersection of clinical data and administrative health data where the eligibility for medically necessary care is determined. He leads a team that provides litigation consulting as well as advisory regarding medical coding, medical billing, medical bill review and HIPAA Privacy and Security best practices for healthcare clients, Meaningful Use of Electronic Health Records. He advises legal teams as an expert witness in HIPAA Privacy and Security, medical coding and billing and usual and customary cost of care, the Affordable Care Act and benefits enrollment, white collar crime, False Claims Act, Anti-Kickback, Stark Law, physician compensation, Insurance bad faith, payor-provider disputes, ERISA plan-third-party administrator disputes, third-party liability, and the Medicare Secondary Payer Act (MSPA) MMSEA Section 111 reporting. He uses these skills in disputes regarding the valuation of pharmaceuticals and drug costs and in the review and audit of pain management and opioid prescribers under state Standards and the Controlled Substances Act. He consults to venture capital and private equity firms on mHealth, Cloud Computing in Healthcare, and Software as a Service. He advises ERISA self-insured employers on cost of care and regulations. Arrigo was recently retained by the U.S. Department of Justice (DOJ) regarding a significant false claims act investigation. He has provided opinions on over $1 billion in health care claims and due diligence on over $8 billion in healthcare mergers and acquisitions. Education: UC Irvine - Economics and Computer Science, University of Southern California - Business, studies at Stanford Medical School - Biomedical Informatics, studies at Harvard Medical School - Bioethics. Trained in over 10 medical specialties in medical billing and coding. Trained by U.S. Patent and Trademark Office (USPTO) and PTAB Judges on patent statutes, rules and case law (as a non-attorney to better advise clients on Technical and Damages aspects of patent construction and claims). Mr. Arrigo has been interviewed quoted in the Wall Street Journal, New York Times, and National Public Radio, Fortune, KNX 1070 Radio, Kaiser Health News, NBC Television News, The Capitol Forum and other media outlets. See https://www.noworldborders.com/news/ and https://www.noworldborders.com/clients/ for more about the company.

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