5 Needed Considerations in ICD-10 Enterprise Risk Management

Enterprise risk management – the rather involved process of minimizing financial risk to capital and earnings through effective organization, leadership, and control – is emerging as a central ICD-10 focus.

Despite hearty preparation efforts, healthcare providers face many revenue cycle hiccups that require immediate addressing as the countdown to October 1 continues. To be ICD-10 ready, healthcare institutions need to actively consider 5 areas of risk management focus, according to Fred DiLuzio, PhD, PMP, ICD-10 Program Manager for Hoag Memorial Hospital Presbyterian, and Michael Roach, Director of Program Management Office at Hoag Memorial Hospital Presbyterian.

“It looks near certain ICD-10 is on course for an Oct. 1, 2015 cutover with the recent joint announcement by CMS and the AMA to provide more flexibility and support during post implementation,” say DiLuzio and Roach.

“Your organization’s 'home stretch' enterprise risk management must embrace the same focus we apply to other large-scale, cross-functional, multi-year initiatives where deliberate and proactive preparations are essential requirements to create the conditions for success,” they add.

The significance of honing in on enterprise risk management is imperative as this ICD-10 home stretch comes to an end shortly. As RevCycleIntelligence.com reported, CFOs are generally disconnected from revenue cycle endeavors. Health systems, nonetheless, are not going to receive payments merely because a patient walks in the door. Here are 5 points to consider:


Keeping your head in the ICD-10 game is key for healthcare providers’ engagement sustainability, maintain DiLuzio and Roach. Considering a BSOS (“Bright Shiny Object Syndrome”) can indeed be a problematic approach, they add.

“Consider incentives for key project members that can include project bonuses and/or the opportunity for other prized assignments conditional on successful completion," DiLuzio and Roach state. “Some turnover and natural attrition are common to long projects; however, maintaining ICD-10 expertise and longitudinal knowledge through the post implementation warranty period is one of your critical conditions for success.”


Communication is essential. As RevCycleIntelligence.com reported, there are many financially grounded misconceptions about ICD-10 that require clarification.

Project meetings and steering committee reviews are a solid start to preparation but are still only one piece of the ICD-10 engagement puzzle, the authors echo. Promoting keen focus on specific ICD-10 preparation endeavors by recognizing and defining concerns keeps those issues that require addressing from becoming buried come October.


“Increase the frequency of ongoing payer-provider communications to ensure ICD-10 readiness on both sides. Your risk focus will likely be on mitigating smaller payers and/or clearing houses that may not have yet demonstrated full readiness to receive ICD-10 claims,” DiLuzio and Roach say.

“In these cases, consider as a condition of success a pre-cutover agreement to contractually require a specific percentage payment pending resolution of claims status within a specified date range (i.e. six months),” they add.


As RevCycleIntelligence.com reported, many denials and rejections are expected following the ICD-10 transition. Knowing what to do in the event such becomes a reality is vital for revenue cycle success.

Nonetheless, implementing a series of mock scenarios, such as what may hypothetically happen following a high claims denial rate, is a suggested strategy to remain properly focused on expected revenue and cash flow aftermath. DiLuzio and Roach recommend business leaders lead these practice sessions to help strengthen revenue cycle come October.


As RevCycleIntelligence.com advised, look within your own staffing needs to confirm who your contacts are, such as determining a payer contact and confirming a clearinghouse contact, to help maintain high ICD-10 preparation levels.

Similarly, do not be afraid to reach out and fill up your contact list, the authors say. “Identify contacts and their information (specific names and phone numbers) from all external business partners who may need to be contacted for issues remediation starting Oct. 1,” suggest DiLuzio and Roach. “Include all payers, vendors, clearing houses, etc., whose scope includes ICD-10 payments and data transfers with your organization. Confirm and document each partner’s own ICD-10 support process and escalation path in advance,” they add.


Taken from the original article by Jacqueline DiChiara / RevCycIeIntelligence.com