6 planning considerations for the ICD-10 deadline extension

Deadline extensions are used greeted with a sigh of relief, if not outright celebrations. Not so with the recent ICD-10 compliance extension to October 2014. Due to all of the other interlocking projects and initiatives many healthcare organizations have going, the complexity of the re-planning is enormous and intimidating. As they say about the ocean, if you are not afraid, you don't understand.

What, then, should be on our list of considerations as we step back into planning mode?

First, a quick overview of ICD-10. Skip the following paragraphs if this is old news for you …

ICD-10, a medical classification and diagnostic coding system, is indeed old news, although its implementation in the US is not. Its development by the World Health Organization (WHO) started in 1983 to replace ICD-9, which was developed in the 1970's. The rest of the world has been using it for awhile and the US is playing government enforced catch up via HIPAA mandated code.

ICD stands for the International Statistical Classification of Diseases and Related Health Problems. It codes for diseases, symptoms, abnormal findings, complaints, social circumstances, and external causes of injury or diseases. It is not only about coding reimbursements. You don't have to think hard to come up with significant and meaningful reasons to get the nation and indeed the globe on a consistent, sophisticated diagnostic standard and tool. The capture, analysis and actions taken from that data could eventually be transformative to world health.

Going from ICD-9 to ICD-10 is quite a stunning leap. It isn't just the straight increase in classifications and codes; it is the combinatorial explosion that results. According to Gartner, the ICD-10 upgrade translates to:

  • Twice the diagnostic codes
  • 20 times the injuries
  • 50 times the procedures

Then why not cheer the compliance deadline change? It does, after all, give us more time to work on this implementation nightmare.

The ICD-10 move is one of a massive number of changes in healthcare that are going on simultaneously. Change one piece of the puzzle, and all work must be re-examined and extended. All estimates are wrong. All resource plans are wrong. All budgets are wrong. Great news for consultants. For the rest of us, not so much.

How, then, to use the time wisely?


Spend a staggering amount of time in planning. Whatever you think it should be, double it. It is ironic that we are knowledge workers that don't have time to think. Insist on investing time for planning. Schedule regular plan checkpoints to take assessments and make adjustments.

Take a look at the suggested timelines laid out by the CMS (Centers for Medicare and Medicaid Services) for a 2014 implementation deadline. This is just a generic starting point and desperately needs the reality check of your experience and customization to your own complex hive of interconnected systems and initiatives.


Remember the combinatorial explosion of twice the codes, twenty times the injuries and fifty times the procedures mentioned above? Add – or multiply? – the number of external partners and interfaces into the mix, and the number of testing scenarios goes nuclear. Invest more in testing.

Build in contingency so when the push comes to shorten your testing plan – and it will – you'll be ready. Testing, and therefore quality, too often becomes sacrificed to make the overall deadline. I have yet to see an instance where that is a good thing.


Gartner estimates that it will take 3 years for normal coding efficiencies to return. 3 years! Error rates, claim denials and litigation are all estimated to significantly increase. Therefore, training, sometimes a lame afterthought, deserves a second, third and fourth look. As long as you are reconfiguring the plan, get more muscle here.

Risk management

And if there was ever a time to get good at risk management, this would be it. This is a vast discipline worthy of a book v. blog. I would, however, point to one key risk area: resources. Will key resources go away? What is your resource contingency plan?

Financial impact

What is the financial impact of all of this? Check not only the increased hours in your spreadsheets, but also review your consultants' contracts and look to negotiate.

And the dual processing costs will be colossal.

Consider how this extended timeline could impact your funding. If work dips, could funds be diverted?

Opportunity …

Does this timeline extension provide an opportunity for new technologies, tools or approaches? At what value and cost?

… to drink?

Then have a drink and consider the following: the World Health Organization expects to endorse ICD-11 in 2015 with US implementation in 2018 … Government regulations won't let us wait and skip to ICD-11, though.

I won't be retired by then, but will, perhaps, have gone mad …

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