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December 16, 2002

Preparing for ICD-10-PCS
By Thelma M. Grant, MBA, RHIA,
Sharon R. Powell, RHIA, and
Barbara Steinbeck, RHIT

With the expected advent of ICD-10-PCS in approximately three years, the current inpatient procedural coding system will undergo a massive change. Based on experience with changes to diagnosis-related groups (DRGs) and ambulatory payment classifications (APCs), the transition will be even more challenging. Although several years away, ICD-10-PCS’s multiaxial structure and data requirements necessitate early education and department application to accomplish a successful transition. Additionally, the potential financial and clinical impact of this upgrade means that institutions need to take steps now to prepare for the challenges that await them.

An overview of the fundamental structure of ICD-10-PCS, including the industry drivers that led to its development as a replacement for ICD-9-CM procedures, should illustrate the challenges expected from the new system. There are steps HIM professionals should take to assess their organizations’ implementation risk as well as strategies, including budgetary considerations, staff education, information systems issues, and the creation of a multidepartmental implementation task force.

A Brief History of ICD-10-PCS
The National Center for Health Statistics developed ICD-10-CM diagnosis codes, an adaptation of the World Health Organization’s ICD-10, for use in the United States. Because ICD-10-CM would not include a procedural coding system, the Centers for Medicare & Medicaid Services (CMS) recognized the need to develop a replacement for the procedure section of ICD-9-CM. The framework for this new system was to come from the National Committee on Vital and Health Statistics (NCVHS), which defined the essential objectives for the procedural system as completeness, expandability, being multiaxial, and using standardized terminology. These four characteristics would result in a unique code for all substantially different procedures.

The CMS funded a three-year project with 3M Health Information Systems to meet the requirements of NCVHS. The ICD-10-PCS system development was completed in 1998. A May 2001 public hearing on ICD-10-PCS as the national standard for inpatient procedure coding resulted in widespread support of its use from organizations such as the American Health Information Management Association (AHIMA) and the American Hospital Association (AHA).

Prior to the passage of the Health Insurance Portability and Accountability Act (HIPAA), the CMS had planned to implement ICD-10-CM in 2001. This date has been moved back several times due to the passage of HIPAA. HIPAA coding standards cannot be changed unless the CMS goes through the official HIPAA process, which begins with NCVHS hearings and its recommendation to the secretary of Health and Human Services. It is anticipated that these hearings will take place in 2003. The estimated date for implementation of new code sets would then be around 2006.

Characteristics
The goal of ICD-10-PCS implementation is to improve accuracy and efficiency in coding and expand the capability of the system to include new codes. To understand the structure and use of ICD-10-PCS, each NCVHS characteristic should be examined separately.

• Completeness
Completeness means that all substantially different procedures will have a unique code. ICD-9-CM contains procedure codes that combine multiple parts of the body instead of breaking them into individual codes.

• Expandability
ICD-10-PCS expands easily to allow annual code additions, such as new medical procedures. Expanding ICD-9-CM will include an increasing number of code characters.

• Multiaxial
ICD-10-PCS is multiaxial—each of the seven characters has a standard meaning within and across procedure sections. The result is a higher degree of accuracy and precision when assigning a procedure code. Each character has a meaning and can be viewed separately.

• Standardized Terminology
There is a standard meaning for each character. This constant avoids confusion and multiple meanings for the same term and is another factor that contributes to the precision with which a procedure is assigned.

Three general guidelines were followed in the development of ICD-10-PCS:
• The exclusion of diagnostic information from the procedure code allows the procedure code to deliver only procedural information.
• The elimination of the Not Otherwise Specified option because ICD-10-PCS requires a minimum level of specificity to achieve the code assignment, making the option unnecessary.
• The definition of all possible procedures, leading to a higher level of coding specificity.

Structure
ICD-10-PCS has a seven-character alphanumeric structure of 0 through 9 and A through H, J through N, or P through Z (see Figure 1). Each character has 34 values. The letters O and I are not used to avoid confusion; the character Z is used for “none.” Each character must be assigned. The seven characters are defined as follows:

Character 1 refers to the section. ICD-10-PCS contains 16 sections that make up the majority of the procedures normally used in an inpatient setting. These sections are medical and surgical, obstetrics, placement, administration, measurement and monitoring, osteopathic, extracorporeal therapies, aging, nuclear medicine, radiation oncology, rehabilitation and diagnostic audiology (includes physical therapy, occupational therapy, and speech therapy), chiropractic, laboratory, mental health, and miscellaneous.

Character 2 refers to the body system where the procedure is performed. Each section (character 1) has its own list of body systems. These are generally accepted anatomical categories. Some of the traditional body systems may be assigned multiple categories to provide more detail and allow more room to add codes.

Character 3 refers to the root operation, which is the underlying objective of the procedure. Each root operation is given a precise definition to avoid confusion. In the medical and surgical section, these root operations are alteration, bypass, change, control, creation, destruction, detachment, dilation, division, drainage, excision, extirpation, extraction, fragmentation, fusion, insertion, inspection, map, occlusion, reattachment, release, removal, repair, replacement, reposition, resection, restriction, revision, transfer, and transplantation. Each definition defines a complete procedure. Incision (opening) is not a root term and would be included as part of the procedure. Excision (to cut out or cut off a portion of a body part) would be a root operation. Excision may include the use of a laser or a knife and would define procedures such as a partial nephrectomy, wedge ostectomy, or pulmonary segmentectomy.

Character 4 refers to the body part upon which the procedure is performed. The listed parts will depend on the section and body system selected. If the physician does not provide detailed documentation describing the body part, the coder can select a general body part for this character.

Character 5 refers to the specific method or approach by which the body part is reached or exposed during the procedure. Using the medical and surgical section as an example, there are 13 different approaches as well as the option of using the letter Z if the procedure is performed directly on the skin. Examples of three approaches include open, open intraluminal, and percutaneous endoscopic.

Character 6 refers to the use of a device in the procedure. This character specifies only devices that remain after the procedure has been completed. Materials used in the procedure, such as clips or sutures, are not considered devices. This character describes a limited set of root operations, which includes bypasses, fusion, insertion, and replacement. Examples of devices found in the medical and surgical section are drainage device, radioactive element, and autograft. If no device is used in the procedure being coded, the coder will select Z for none.

Character 7 is the qualifier. A qualifier can be used to identify extra information such as the type of transplant or a second site for a bypass. It is specific to the procedure.

Index
The index for ICD-10-PCS provides the first three characters of the code. It then refers the coder to a tabular list location to complete the remaining four characters needed for a valid ICD-10-PCS code. Both the index and the tabular must be used for every ICD-10-PCS code. Eponyms (surgical procedures named after the surgeon who developed them) were eliminated from ICD-10-PCS. The index contains an alphabetical list of primary entries of root operations and composite terms. Composite terms are not root operations, but multiple aspects of a procedure. The secondary entries are specific to the root operation and may include body parts, devices used, or a root operation for revision.

An example of an index entry by root operation:
Bypass
By Body System
Female Reproductive System 0V1
Heart & Great Vessels 021
Lower Arteries 041
Lower Veins 061
Male Reproductive System 0W1
Upper Arteries 031
Urinary System 0T1

For a heart bypass, the coder would look under bypass and select heart and great vessels 021 under body system. The index will then refer the coder to the tabular listing to complete the code.

The tabular listing is formatted in Figure 2.

The top of the grid contains the first two to three characters identified in the index. The rest of the grid allows the coder to make appropriate selections for each of the remaining four characters.

Example of a Completed Code
02100Z4 - Bypass, One Coronary Artery to Right Internal Mammary Artery, Open
Zero stands for the medical surgical section
Two is the heart and great vessels body system
One is the root operation of bypass
Zero is the body part—in this case one coronary artery
Zero is the approach, which is open for this procedure
Z indicates that no device was used
Four is a qualifier for right internal mammary artery

Validation
An advisory panel of representatives from the AHIMA, the AHA, and the American Medical Association provided input during the development of ICD-10-PCS. Formal testing of ICD-10-PCS was conducted in 1998 by the CMS through two phases, the first using two clinical data abstracting centers (CDAC) to evaluate the effectiveness of the system. Each center coded 2,500 records and provided feedback on modifications to the tabular and index sections and training manual.

In the second phase, 200 medical records were coded using both ICD-9-CM and ICD-10-PCS. The systems were compared for ease of use, time needed to identify codes, number of codes required, and the strengths and weaknesses. CDAC coders favored ICD-10-PCS over ICD-9-CM because of its greater specificity in the assigned codes and the increased information available for research and statistical analysis.

IMPLEMENTATION CHALLENGES

HIM Personnel Challenges
The transition from ICD-9-CM to ICD-10-PCS will present many challenges, particularly for HIM personnel. It will require an expanded coder knowledge base, specifically in the areas of detailed knowledge of anatomy and medical terminology; comprehension of operative reports; comprehension, interpretation, and application of standardized ICD-10-PCS definitions; and increased interaction and collaboration with medical staff. This list, while extensive, is not prohibitive.

ICD-10-PCS is a natural progression of increased health information requirements. It will expand the clinical data collected by the individual coder and provide better information at both the facility and national levels. Proficient coders have a solid background upon which to build during the period preceeding implementation. Weaknesses can be identified and addressed by education. Because the most important issue to address is fear of change, an optimistic approach to training, auditing, and education is an important aspect of any implementation plan.

System Challenges
Challenges to a hospital’s information system will arise from the differences between ICD-9-CM procedure codes and ICD-10-PCS. Each system that currently holds an ICD-9-CM four-character numeric procedure code will need to be assessed with respect to its ability to adapt to an ICD-10-PCS seven-character alphanumeric code. Holding these codes and moving them through the various interfaces to the UB92, departmental databases, and decision support systems may become an issue for some facilities. A clear understanding of how these codes will be passing through the multiple interfaces, well in advance of ICD-10-PCS implementation, ensures that no last-minute manual work-around will be required to drop a bill. Every manual work-around costs the hospital time and money.

Storing both ICD-9-CM, ICD-10-CM, and ICD-10-PCS code sets will be required for hospital reporting, research, and trending of clinical and financial data. A crosswalk exists that converts ICD-10-PCS to ICD-9-CM procedure codes. At this time, there is no crosswalk to convert all ICD-9-CM codes to their ICD-10-PCS counterparts because of major changes in the structure for determining the procedure codes. Without crosswalks for code conversion, systems may need to retain the ability to store ICD-9-CM codes for future case mix analysis and comparative studies.

The type of facility and amount of research or clinical reporting that is done on a regular basis will determine how many ICD-9-CM data are archived. Facilities conducting little or no research—and needing to trend only a few years’ worth of data for financial purposes—will complete the implementation period quickly. Research-oriented organizations such as university hospitals, cancer facilities, and children’s hospitals will require more planning and adjustment.

The CMS will likely map codes to their original DRGs during the transition to give hospitals a period of adjustment. ICD-10-PCS and ICD-10-CM codes will map to more appropriate DRGs with different reimbursement levels in subsequent years.

Organizational Risk
The implementation of ICD-10-PCS poses both budgetary and clinical risks to organizations and may affect four crucial areas of a hospital in terms of its departmental budgets and the new system’s role in the overall reimbursement of the facility. These areas are HIM, patient financial services (PFS), hospital finance, and information services (IS).

HIM is the most obvious point of impact because it is the source of coding. Assessing the gap between what is to occur upon ICD-10-PCS implementation and processes currently in place is a critical first step. To begin a gap analysis, coders and coding managers can prepare individually and as a department by selecting a population of medical records and recoding them with the new system.

ICD-10-PCS training manuals are available from the CMS and 3M Web sites. These will help coders determine areas of weakness associated with anatomy or specific surgical processes that will require additional education. Coders will also be alerted to problems with physician documentation. Correct coding with ICD-10-PCS will require more extensive documentation from surgeons, and education may be needed in some facilities to provide information for accurate coding.
An audit will allow HIM directors and coding managers to assess the time needed to code a record, provided the appropriate documentation exists and the coders are sufficiently trained. An important component of this assessment is the medical/surgical ratio within the facility.

The number of procedures generating DRG-driven reimbursement should be factored into the departmental picture. If the facility has a 60:40 ratio, where 40% of its DRGs are driven by procedure codes, the rule of thumb is that more than one-half of the facility’s reimbursement is tied to procedural coding. The question to be answered is: If 40% of the coding is slowed by X amount of time, how many additional coders will be needed to maintain an acceptable accounts receivable during and after implementation?

PFS needs to be completely aware of potential slowdowns in HIM. These slowdowns may affect monthly summaries, operational reports, and accounts receivable. Many HIM departments use the “first in, first out” method of determining coding priority. This, however, may not be the most cost-effective way for the facility to continue to bill. With the help of PFS, the HIM department can prioritize its charts by categories such as payor filing date, high-dollar stay, and chart availability.

Hospital finance departments use an assortment of reports and summaries featuring DRGs for contract negotiation, resource utilization, cost management, strategic planning, and other functions. These reports are the lifeblood of the facility, and potential slowdowns in their generation could be problematic. While PFS is concerned with the speed of DRG submission, finance is concerned with the content. An inventory of all reports going to finance and containing DRG information should be compiled and examined to determine areas of risk during the implementation period.

The hospital information systems department is responsible for maintaining an inventory of all systems that will carry the ICD-10-PCS codes, interfaces that will pass them, databases that will hold them, and an assessment of the level of technical risk within each. IS will interact with all vendors to assure each provides an update to the current system. In very large facilities, additional employees might be required for this task. IS will coordinate the actual implementation and decide on additional system storage needs.

Clinical Issues
The transition to ICD-10-PCS may raise two clinical risks within facilities: changes in reports produced for individual departments and the effect of the new coding structure on physician documentation.

Reports generated for individual departments are used in many facilities for Joint Commission on Accreditation of Healthcare Organizations (JCAHO) reporting, research, clinical pathway development, and resource utilization. All reports containing procedure codes and related DRG information that go to department heads should be inventoried and analyzed for areas that will change with ICD-10-PCS. Individuals running these reports should be updated on changes that would result with the code-set transition. They should be aware of a report’s use and how the change might affect the information and the clinical picture that is being presented.

Physician documentation touches all areas of the facility—from the clinical picture being portrayed to the reimbursement received for services. Physician documentation has been an ongoing problem since the beginning of the 1900s when the medical record profession was given responsibility for patient records and the information within. The situation has not improved much over the years, despite all the programs designed to address the issue. With ICD-10-PCS, documentation problems will increase because of the expanded requirements for code assignment. Incorrect code assignment, especially in the second year, can significantly change the clinical picture of a department, the reimbursement to the facility, and the professional profiles of the physicians. HIM directors and quality management directors should be prepared to aggressively address this issue with administration.

PREPARATION STRATEGIES
A three-pronged approach to ICD-10-PCS implementation includes the formation of a facilitywide task force, concentrated education, and interaction with regulatory agencies.

Education
Topping the list of the most important aspects of implementation is education. Four areas requiring extensive education are the HIM department, medical staff, quality management reviewers, and physicians. Education for all four should include the basic structure of ICD-10-PCS and the expanded requirements for assigning a procedure code.

Each area will approach education from a different perspective. Coders need to increase their medical knowledge, physicians need to understand the requirements for documentation, and the medical staff needs to be aware of the challenges to the physicians and be supportive of processes that allow greater interaction between the coding staff and the physicians. Quality management needs to understand ICD-10-PCS and how it relates to its data collection, reporting, and JCAHO requirements.

Implementation Task Force
The creation of a multidepartmental task force will provide the facility with processes to address each area of risk and concern. Representatives on this task force and the associated activities should include the following:

HIM
• gap analysis conducted on current records to determine coding and documentation weaknesses
• determination of staffing requirements
• education of coders
• inventory of reports
• billing process assessment/change with PFS
• processes designed for coder/physician interaction

PFS
• billing process assessment/change with HIM
• inventory of processes, such as monthly summaries, that might be affected by ICD-10-PCS

IS
• inventory of all software that carries procedure codes
• map of interfaces, tables, and information flow
• contact with vendors for affirmation on upgrade to ICD-10-PCS
• determination of staffing requirements

Medical staff
• education
• supportive processes for HIM and physicians

Physician champions or liaisons
• education
• interactive processes with HIM

Quality management
• education
• inventory of reports

Hospital finance
• education
• inventory of reports
Additional team members may include representatives from other areas, such as compliance or case management, depending on their role within the facility.

While the leadership position should belong to HIM, all areas play a vital role in a successful transition. ICD-10-PCS can also be viewed as an opportunity to break down the silos that exist within hospitals and produce a smoother workflow that generates better, more useful health information.

Permission Statement:
Portions of this article were published in the 2002 AHIMA National Convention Proceedings. Reprinted with permission from the AHIMA. Copyright © 2002 American Health Information Management Association. All rights reserved.


— Thelma M. Grant, MBA, RHIA, is senior product development specialist for the 3M Health Information Systems (HIS) clinical research department. She assists in the design and development of new diagnosis and procedure coding schemes, including ICD-10-PCS, under contract to the Centers for Medicare & Medicaid Services (CMS).
— Sharon R. Powell, RHIA, is inpatient domain marketing manager for 3M HIS, with responsibility for defining inpatient care markets, understanding government regulations, and identifying customer needs for
the acute care market.
— Barbara Steinbeck, RHIT, is clinical research manager for 3M HIS and is responsible for managing federal and state contracts for the development of coding and classification systems, including the CMS diagnosis-related groups and the ICD-10 procedure coding system.

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