With ICD-10 rollout past, healthcare providers brace for quality coding deadline

While the changeover to ICD-10 has gotten most of the attention, there are even more coding challenges on the horizon as providers prepare for mandatory quality reporting measure set to begin in 2017. As with all of healthcare, coding is now moving toward quality. And what has to this point been optional, next year will become required.

While the practice has been optional so far, in early 2017 providers must submit four of their inpatient quality reporting measures electronically, dubbed eCQM, or they will receive a 25 percent reduction in their Centers for Medicare and Medicaid Services market basket update in 2018.

"That could translate into a couple of million dollars for a mid-sized hospital," said Tony Panjamapirom, senior consultant of research and insights at The Advisory Board. "It can be the deal breaker between black and red in their bottom line."

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Providers will be able to choose from their third or fourth quarter data in 2016 to submit in February 2017. While this may seem like a long way out, providers can be thinking now about ways to prepare.

The first thing all providers have to figure is whether their electronic health records vendors will be prepared for eCQM electronic submittals. Hospitals are going to be required to use the most recent version of CMS' electronic specifications each year and many vendors have older versions certified. This can keep providers from meeting electronic submittal guidelines, Panjamapirom said, so they will have to be proactive about getting annual updates from vendors to make sure they comply with updates.

"A lot of vendors are communicating with their clients about how they are going to keep up-to-date with what CMS requires and some vendors don't have a plan and don't know what they are going to do with it," he said. "Vendors have a little less than a year to get ready to start Q3 reporting electronically."

Andy Weissberg, senior vice president of marketing and communications at Quantros, a healthcare IT provider, said not all EHRs are ready to submit electronically. Some vendors are certified for a handful of measures, but not for all of them. Health systems will have to choose measures that vendors are able to capture and process.

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Helen Bremford, delivery director for advisory services at CTG Health Solutions, said organizations should also chose measures they are familiar with and where they excel. One of the benefits for providers initially is there won't be thresholds with the four reporting measures, Bremford said. When providers send their quality data, they don't have to worry about whether they are meeting certain guidelines … yet.

"That will come," Bremford said. "If everyone is submitting these numbers, CMS will stratify them and start to measure them and providers have to be prepared for that."

Providers need to start analyzing this data and start making efforts to improve their performance. And as CMS goes, so too do other payers. Bremford said providers should expect other payers to begin analyzing this electronic data and tying reimbursement to those numbers down the road.

Choosing quality measures that score higher will not only put a group's best foot forward, but will enable them to see if there are holes in the data. For instance, if an organization estimates that 90 percent of patients are receiving diabetes education, but reports show that only 50 percent are, there may be a data problem.

Weissberg said eCQM electronic reporting will demand data precision from the beginning of the patient encounter. Incomplete charts will not be assumed by CMS, he said.

And there is more likelihood that charts will be incomplete when submitted electronically. When coders previously extracted from charts, they were able to fill in holes during the CMS input process. If data is taken directly from the EHR, there is a smaller window to correct it.

There will also be a need for greater documentation under the new system, Weissberg said. Patient demographic information like age, sex and ethnicity will be required when submitting electronically. Each facility that an encounter occurred will also be required as well as things like where a prescription was written.

"There is a level of precision that, in the beginning stages, clinicians are going to have to adapt to," he said. "You can have the best EMR in the world, but if you don't have a system of coding at the point of care, the ramifications are enormous now in the electronic world."

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It will take a system-wide approach to make sure providers are properly reporting eCQM electronically. Panjamapirom said in early validation, they have found that data is often missing in charts. Whether providers aren't collecting or documenting it or nurses are missing elements, there are a host of issues, he said.

"People will have to work with the clinical departments to communicate importance of good data – once again – and will have to work with EMR providers to make sure it makes sense from a clinical and collection data perspective," he said.

Bremford said providers will need to get the right team of people together to collect and report data. The clinical side is going to have to join with IT, quality and informatics, she said.

"They will be working together to understand data from start to finish," she said. "And then they will have to take the next step of analyzing and understanding it and moving toward rapid performance improvement."

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