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The Challenges of Implementing ICD-10

Terry Amiel, MD
11/20/2009

I recently tried to estimate what financial affect the implementation of ICD-10 on its own would have on my practice. I own a small urgent care, own my own building, employ one full-time and one part-time nurse practitioner and operate on a very lean budget. We have been open for four years and operate seven days a week, 8 a.m. to 8 p.m. on weekdays and 10 a.m. to 8 p.m. on weekends. We have approximately 2.4 FTEs per provider including my wife who is an RT and takes care of our X-ray department, lab and CLIA specs, is our OSHA queen and cleans toilets. I do maintenance and medicine and all staff members pitch in for janitorial services. My income would be considered modest by primary care standards.

In considering the cost of bringing in the new ICD-10, one has to consider two other requirements the government is planning to initiate over the next five years. All medical practices that bill Medicare will be required to install and “meaningfully” use electronic health records (EHR) by 2014, and the new addition to HIPAA of the Red Flag Rule (which was delayed until Nov. 1, 2009). This rule addresses the financial aspect of identity theft in any institution that accepts payments over time instead of on a cash-only basis. This would then include most, if not all, urgent cares unless they do not accept Medicare and accept cash-only at the time of service.

The start-up costs for ICD-10 will include training my billing-and-coding staff, which for me is my office manager and my coding clerk, both of whom also cover as receptionists. There is a coding class for ICD-10 being offered locally for $1,600 per person and involves 200 hours of training time. ICD-10 is a far more complicated system than is ICD-9 and requires a much greater degree of specificity on the part of the provider in order to code correctly and ultimately receive reimbursement from Medicare and all third-party insurers.

I’ve heard estimates that this will increase the time involved in adequate documentation from two to five minutes per patient on the part of the provider. As we see about 30 patients a day, this could translate to an extra 60 minutes of my time and thus I would lose two to three patient visits a day, conservatively speaking.

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