ICD-10 Implementation and Interoperability

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.

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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