The pressure escalates for many physician practices as the January 2012 HIPAA version 5010 electronic transition standards deadline approaches, and ICD-10 is looming right behind with an implementation deadline of October 1, 2013. The problems many practices are facing in the advancement toward testing and implementation extends beyond the boundaries of the practice walls. But this doesn’t provide an excuse for preparation to be pushed to the side.
For those of you who need a gentle reminder, or some who may not be aware, the timeline for HIPAA 5010 is summarized below:
- 2010 : 1/1 Begin Internal Testing (Level I)
- 2011 : 1/1 Begin Testing With Trading Partners (Level II)
- 2011 : 1/1 Accepting New 5010/D.0 Versions; 4010A1/5.1 continues
- 2011 : 1/1 Begin Initial ICD-10 Compliance Activities (gap analysis, design,
development, and internal testing)
- 2011 : 12/31 Complete Partner Testing and Dual Process
- 2012 : 1/1 Cut Off Date for 4010A1/5.1 Transactions
- 2012 : 1/1 Full Compliance
- 2013 : 1/1 Begin Internal Testing (Level I)
- 2013 : 10/1 Compliance Date for ICD-10-CM and ICD-10-PCS
According to the HIPAA 5010 implementation timeline, we should be in the external testing phase with payers at this point. However, a recent survey conducted by the Medical Group Management Association (MGMA) indicates that an alarming number of practices are not ready to comply with the deadline. Many have not yet completed system upgrades necessary to perform internal testing and are not ready to conduct external testing with external payers.
Results of the MGMA survey indicate that 29 percent of respondents believed their current practice management system software would allow them to use Version 5010, and 50.3 percent of respondents stated that their software would involve an update. In addition, 4.5 percent indicated that their software would need to be replaced. More than 30 percent of respondents indicated that they had not received any communication from their practice management software vendors regarding the change to Version 5010.
With regard to implementation, 45.2 percent said that they have not started their implementation of Version 5010; 45.9 percent have partially completed implementation; and only 2 percent reported that they had completed implementation (which means that a whopping 98 percent have not yet fully completed implementation).
Taking a deeper look into testing, 38.2 percent of respondents indicated that internal testing had not yet been scheduled, and 40.8 percent said they planned to start testing between March 2011 and December 2011. Another 2 percent did not plan to start internal testing until after January 2012 (the deadline for compliance with the new standard), while 9.2 percent of respondents had started to test.
MGMA president and CEO William F. Jessee, MD, FACMPE, has expressed his concern.
“We are growing increasingly concerned regarding the ability of medical group practices to meet the Jan. 1 deadline. Our research indicates a significant number of practices have been forced to wait for their practice management system software vendors to make the required modifications before they can begin to test with clearinghouses and health plans,” Jessee said.
More information pertaining to the MGMA survey can be found at www.mgma.com/press in a news release dated June 15, 2011.
So how do practices step up to the plate in their efforts to move forward at a fast pace? Chances are, you are among the 98 percent of practices that are not yet fully compliant and have not yet completed testing (or may not have even begun the internal testing phase).
Regardless of where you are in the process, here are a few suggestions to help you in your fast paced, six-month journey to HIPAA 5010 compliance:
(1) Take one step back and determine where you are in the process. Make note of all software affected by HIPAA 5010. Develop implementation and testing goals and communicate these throughout your organization. Document achievement of goals/milestones and share your successes, celebrate within your organization as you reach or attain the goals.
(2) Prepare a current workflow analysis, keeping in mind that HIPAA 5010 will affect all areas of your organization. Develop what you expect the post-HIPAA 5010 workflow to look like. Document this in a flow chart or other format so that you can monitor and adjust your future workflow accordingly.
(3) Reach out to your software vendors to determine what types of changes, upgrades, etc., need to be made and ask them to provide you with written documentation of their commitment and timeline for making these changes. If you are unsuccessful in your efforts to communicate effectively with your vendors, consider enlisting the help of your local MGMA chapter with putting a little pressure on them with regard to compliance.
(4) As we all know, any type of change typically affects cash flow and HIPAA 5010 is no exception. Contact your payers now to determine the impact of testing on the payment process. Develop contingency plans for reductions in cash flow (increase your current line of credit and tighten up on your front-end collection policies). Monitor cash flow before, during and after the transition to HIPAA 5010 to reduce any unanticipated disruptions resulting from the implementation process.
One final thought to give consideration to – many organizations are incorporating the ICD-10 changes in the HIPAA 5010 process. Perhaps your organization should take the opportunity to kill two birds with one stone and tackle it all at once, too. As a result, you’re strategically placing your organization ahead of the curve in meeting the October 1, 2013, deadline for full compliance with ICD-10.
Sharon Walden, CPC, is a healthcare manager in HORNE LLP’s Baton Rouge office. She provides consulting services to hospitals, healthcare entities and physician group practices on operational, compliance and revenue cycle matters. HORNE is one of the top 50 accounting and business advisory firms in the country and one of the largest firms in the Southeast dedicated to the healthcare industry. For more information on HORNE, visit www.horne-llp.com.