The EHR and ICD-10 Connection

An article by Ron Sterling from the January/February 2012 issue of HBMA Billing.

The upcoming ICD-10 start date of October 1, 2013 creates a critical path that can affect the EHR strategy and plans of you and your clients.

For many third party billers and their clients, the months leading up to ICD-10 start date will be focused on two major tasks.

• Implementing last minute changes to EHR systems and interfaces with practice management systems. EHR systems currently use ICD-9 codes for a variety of purposes. The use of ICD-10 codes in place of ICD-9 codes could have a variety of unintended consequences and force substantial changes in EHR systems. For example:

1. Many EHR systems leave the coding of modifiers to the companion billing systems. If the ICD-10 code is determined by the EHR, then the EHR should also establish the matching CPT codes and modifiers.


2. ICD-9 codes are used to organize the patient record and support coding of charges. For example, many EHRs use ICD-9 codes to index patient problems, which can have associated prescriptions, orders, and images. If the ICD-9 classifications are switched to the ICD-10 system, then the relevant parts of the ICD-10 codes will vary for the related ICD-9 classification.


3. ICD-9 codes associate related visits and other information within the EHR. For example, you can view all exams dealing with a specific ICD-9 code. If ICD-10 codes are used, the EHR will need a facility to relate the relevant portions of those codes with historically-classified ICD-9 information.


4. ICD-9 codes trigger patient care items. For example, an ICD-9 code for diabetes may trigger a health maintenance item associated with a periodic lab test. The logical constructs used by EHR systems will have to be reworked in order to be triggered by new ICD-10 codes.

• Implementing changes to PMS and billing procedures and systems. In addition to focusing on correct coding, third party billers and practices will want to closely monitor the performance of their clearinghouses and payers for initial problems and evolving issues in the switch to ICD-10. For example, payers may strengthen the edits between the ICD-10 and CPT codes over time. Third party billers and their clients may have to deal with an ever increasing number of payer specific requirements.

With this substantial body of work waiting to be completed, third party billers and their clients cannot assume that conversion of paper patient records to EHR projects can be accomplished in the same time frame. Indeed, proper completion of a practice's EHR implementation may be a critical path item to start the rollout of that client's ICD-10 solution.

Third party billers should work with their clients to pace the implementation of EHR strategies for a smoother transition throughout the ICD-10 process. Practices may fail to meet the ICD-10 requirements and disrupt cash flow after October 1, 2013 and third party billers may be unable to pursue EHR opportunities when the ICD-10 transition is underway. Consider the following timeframes as you plan your internal strategy or in your work with your clients:

• Selection of PMS and EHR products can take 2 to 4 months or more before a decision.


• Contract negotiations and planning can consume another 30 days.


• Implementation of an EHR can take 4 to 6 months depending on a variety of policy and implementation issues. For example, it can take 30 to 60 days to install the hardware base and provision upgraded communications.


• Once the EHR implementation is complete, a practice will need 4 to 8 months to transition individual patients to the EHR.


• If you are considering a new billing system as part of your EHR project, allow an additional 4 to 6 months for the project.

A full PMS / EHR project can take anywhere from 10 to 18 months or more. Considering that practices and your organization should be ready to focus on ICD-10 by the beginning of summer, 2013, it is not too early to tackle the EHR project on your critical path to ICD-10 compliance.

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