ICD-10 The Different Dimensions of Business Continuity Planning Presented by Mike Arrigo Managing Partner, No World Borders [email protected]July 21, 2011 WEDI Implementation Forum Advancing Down the Implementation Highway: Merging into 5010 Compliance, Shifting into ICD-10 http:// www.noworldborders.com 1
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ICD-10The Different Dimensions of
Business Continuity PlanningPresented by Mike Arrigo
Training evaluation shows lack of knowledge (by 12/31/2011).
Retrain as necessary
Providers are not ready to submit ICD-10 codes
Provider assessments and external testing show lack of provider preparedness.
1.Assure systems can handle ICD-9 for post 10/1/2013 services/prepare business continuity plan
2.Work with ClearingHouseX and others to move providers forward
Vendor readiness / capabilities don’t meet SLAs
Vendors do not deliver ICD-10 ready products by agreed upon date or do not provide the appropriate functionality.
1.Look for alternative vendors
2.Develop in house capability
3.Negotiate acceptable revised dates and monitor
4.Dashboard of delivery dates
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ICD-10 Key Risks (page 2 of 3)
Excerpts from f 25 Risk Assessment Areas
10
Risk Risk Trigger Event Remediation / Mitigation
Payor financial risk – payments are significantly higher than anticipated
Benefit payments for post Oct. 1 2013 services from Oct. 1 – Dec. 31, 2013 significantly higher than anticipated and impact HealthCo ability to pay.
1.Assure sufficient cash reserves prior to Oct 1, 2013
2.Possibly acquire line of credit
3.Negotiate contingencies with providers
4. Understand changes to DRGs, Case Rates, APGs
Provider financial risk – reimbursements are significantly lower than anticipated
Benefit payments for post Oct. 1 2013 services from Oct. 1 – Dec. 31, 2013 significantly lower than anticipated and impact provider’s ability to operate as a business.
Before Assessment During Assessment Remediation Plan thru October 1, 2013
While HealthCo made great strides in the last 90 days, the organization must continue forward progress.
1.HealthCo had low awareness of impact and opportunities of ICD-10.
2.Too many answers were in the “Don't Know” category in the web survey.
3.Urgency for change appeared quite low.
4.Communication levels re: ICD-10 seemed to be very low.
Ensure regular project management, governance, and requirements development activities are initiated immediately.
These activities must be reviewed monthly and quarterly, with regular management oversight.
Failure to start these activities will result in regression to where the organization was in August 2010.
Training plans as recommended should be prioritized by functional area.
Continue Business Roadmap activities for areas not yet prioritized:1. Plan2. Prioritize3. Prerequisite plan4. Implementation plan for prioritized items
Overall ICD-10 Implementation:1. Steering committee meeting schedule2. Establish project management coordination group3. Establish implementation team org chart, team roles, 4.Recruit, retain, identify team members5.Iterative review and editing of the project timeline
Determine ICD-10 work coordination process:1. Frequency of communication, coordination of issues2. Project governance and standards3.Development and review of requirement artifacts
ICD-10 and Documentation Provide audit trail of assumptions
Mitigate punitive regulatory impacts
NAIC Audit Rules, Sarbanes Oxley – Revenue impacts– Medical Loss Ratio
Selected areas for document trail– Board and management minutes– Risk assessment and documentation– Business continuity plan documentation– Back up procedures– Service provider contracts, SLAs– Testing plans
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What’s next?
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Discovery & Remediation Tools:•COBOL•.NET•Java
9 to 10 Frameworks:•Vocabulary •Concepts•Consortiums