PM&R In Practice: Implementing ICD-10: How Can You Prepare?

UPDATE: A bill that avoids a 24 percent Medicare physician payment cut and keeps rates flat for 1 year passed the U.S. Senate and House in March 2014. The bill also delays the compliance date for the International Classification of Diseases, 10th Edition Procedure Coding and Clinical Modification (ICD-10) until 2015

To begin project planning, keep these 5 areas in mind to ensure you are well prepared.

1. General Assessment

The initial stepping stone to implement ICD-10 is to become familiar with what ICD-10 is and how it will affect the hospitals, private practices, and medical centers that physicians interact with on a daily basis. This transition will be necessary for all health professionals who fall under requirements of the Health Insurance Portability and Accountability Act (HIPAA), not just those health care providers who submit claims to Medicare and Medicaid. This is a widespread change that will affect health care providers, payers, clearinghouses, and billing services, among others. Thus, it is fundamental to learn about the structure, organization, features, and system impacts of ICD-10.

Now is the time to identify your current systems and work processes that use ICD-9. Many health care providers have already begun to look at their operating systems and software packages to make necessary changes that will ensure a smooth transition. Check your existing clinical documents (e.g., encounter forms/superbills, practice management systems, electronic health record system, contracts, public health and quality reporting initiatives). Wherever you see current ICD-9 codes being utilized, note that ICD-10 codes will need to be substituted.

2. Systems Outlook

A key aspect of this initial assessment is determining if you currently have Version 5010 systems and transaction standards. For those unfamiliar with Version 5010, it is the new, updated set of transaction standards that everyone who submits claims electronically will need to have. Those who have been submitting claims electronically the last few years have done so utilizing Version 4010/4010A. Electronic claims submitted on or after January 1, 2012, must use Version 5010. After January 1, 2012, electronic claims that do not use Version 5010 standards cannot be paid. To allow time for testing, the Centers for Medicare & Medicaid Services will accept electronic claims using either Version 4010/4010A or Version 5010 standards from January 1, 2011 through December 31, 2011.

3. Budget

As with any long-term strategy implementation, planning is essential. Start talking to your billing services, clearinghouses, and any software vendors that you work with to ensure they are ready to provide the services and support that you will need in the coming months. Your vendors will be able to give you insight on any system upgrades or replacements needed to accommodate Version 5010/ICD-10. Keep these questions in mind:

  • Will upgrades be covered by existing contracts? (costs involved for upgrades)
  • What is the minimal testing period required? (determine timeframe required for implementation of new systems by your vendors)
  • Will vendors offer support and training for your staff?

Once you have determined what costs are involved to achieve compliance in a timely fashion, set aside a budget for implementation. Note: You may need to revisit and reassess your budgetary needs throughout the project. Plan on expenses for system upgrades and changes, ancillary resource materials, staff training, and vendor contracts.

Contact your payers to inquire how ICD-10 implementation will affect your existing contracts. Inquire if you will need to re-negotiate your provider contract or electronic data interchange (EDI) agreement and ask if payment schedules will be modified. Be proactive by contacting organizations with which you conduct business; ask what they are doing to achieve compliance and what steps they have taken to be prepared for the transition.

4. Staff Training

You will also need to assess your staff training needs and determine changes to work flow and business processes. Clearly identify key members on your team who will need to know the new codes, and prepare to provide them with the appropriate training guidelines. Take advantage of the wide variety of opportunities to receive training through Webinars, professional association seminars, online courses, etc.

5. Sufficient Testing Time

To ensure that everything will work smoothly, sufficient time should be set aside to test that upgrades and systems are fully functional and that appropriate exchanges are occurring with trading partners. Implementing ICD-10 should not be viewed as just an IT project. It should be understood that this will impact your current business process and may impact other operating systems.

Remember: Now is the time to prepare. January 1, 2012, and October 1, 2013, are definite dates determined by the US Department of Health and Human Services (HHS); HHS has no existing plan to extend or delay those dates. For more information and resources, visit,, and