ICD-10 Implementation Plan

ICD-10 Implementation

With only a few weeks left until the official launch date of ICD-10, there are still many providers who aren’t yet ready for the implementation. Will it be impossible to implement ICD-10 in the time that’s left? Here’s your rapid rush guide to ICD-10 implementation.

(Steps 1-6)

Ideally your planning and contacting vendors should take up to ten days at max

(Steps 7-10)

Spend the remaining twenty days in training your staff and testing internally and externally to get up to speed with ICD-10.

1)Appoint an ICD-10 Commander

It’s really important you choose someone at your office to lead the transition. If you have a practice manager, he or she would obviously be made ICD-10 commander. If you don’t have a practice manager, it could be anyone (or a team of people) who possesses leadership skills and, more importantly, enthusiasm. Most of the people in your office (yourself most likely included) find this whole ICD-10 transition a bit of a nightmare, so your commander should definitely be able to boost morale and sing the praises of the new code set.

Help your commander by collecting comprehensive educational material from the CMS website and other online resources and offering it to them. This way they can quickly digest the information and be able to pass it onto the rest of your staff.


  • Identify key personnel involved in the ICD-10 implementation plan

  • Set a schedule for project meetings

  • Begin preliminary budget for implementation costs, e.g., software upgrades, hardware upgrades, training, new forms, resource materials, etc.

  • Plan for office communication on project

2) Examine Your Current Processes

Don't worry, there is still time for you to examine your current diagnosis coding processes and conduct your own ICD-10 compliance audit. This step is fairly straightforward: you’ll simply want to take a hard look at the processes you currently have in place and ask yourself if they will accommodate the new codes. You’ll also need to consider whether or not you’ll have to hire a new coder, even if it’s only temporarily during the initial transition.


  • Determine which code sets you need to implement, ICD-10 diagnosis only or both the diagnosis and procedure

  • Identify and list all work processes that use ICD-9 today e.g.

    • Patient registration and scheduling

    • Clinical documentation/health records

    • Referrals and authorizations

    • Order entry

    • Coding

    • Billing

    • Reporting and analysis

  • Identify and list current electronic systems that use ICD-9

  • Identify all staff who work with ICD-9 and exactly what they do related to ICD-9 and ICD-9 coding

  • Identify possible work flow changes you will need to make to implement ICD-10, e.g., data collection forms; encounter forms, superbills, etc.

3) Contact Your Systems Vendor(s).

Contact your vendor and ask them if they will be upgrading your system (e.g., hardware and software) for ICD-10


  • Various forms can be utilized to guide discussions with vendors, clearing house and billing services. These can be found online in CMS’s Road to 10’s Template Library

  • Verify twice that you’ve correctly identified systems which use ICD codes e.g., EHR and Practice Management systems

  • Ask if your system will be able to do dual coding of ICD-9 and ICD-10 in order to submit transactions for services that were provided before October 1, 2015 but are submitted after that date

  • If your system will not be able to continue dual coding in ICD-9 and ICD-10, you will need to consider how these transactions will be submitted after October 1, 2015

  • Ask if there will be any charges for upgrading your system and/or software for ICD-10 (Under your contract, upgrades to meet mandatory requirements may be free of charge)

  • Ask for an estimated timeframe of when they will install your system and/or software upgrades

  • Determine estimated system downtime during upgrade

  • Determine if you need any new hardware to support ICD-10

  • Update contracts with vendors and health plans as needed

  • Remember to use ICD-10 codes for all services rendered on or after October 1

  • And use ICD-9 codes for all services provided before October 1

4) Budget for Implementation Costs

No matter how prepared practices try to be, there will inevitably be denied claims and a slowdown of processes within your own staff as everyone tries to get up to speed. Both of these will cause you to experience a decrease in revenue. On top of this, you might be ready but if your payers aren’t, your income will still take a hit. For all of these reasons its best to prepare for the worst case scenario.

  • Experts have recommended saving up to six months of cash revenue to keep your practice afloat. Obviously if you haven’t done this yet it may be difficult to do so in the next 45 days.

  • Your other options would be to talk with your bank about a loan or an increased line of credit to help get you through this potential financial crisis. Don’t put this off. The longer you wait to get available financing the higher your interest rates may be.

  • And finally, while you’re dealing with your finances, you’ll want to establish a budget that takes into consideration any software changes, new hardware, staff training, resource materials, testing, consulting services, decreased productivity, etc.

5) Implement System Upgrades

Installation of software upgrades by your vendor (Remember that your vendors will be coordinating implementations with all of their customers)

6) Contact your Trading Partners


  • Ask trading partners when they will be ready to send and receive test transactions with ICD-10 codes (You will want to exchange test transactions prior to going live to avoid claims processing interruptions.  Work with your high volume and/or high dollar trading partners first)

  • Ask your payers if you will need to re-negotiate your contracts with them based on the implementation of ICD-10

  • If "yes", determine if the re-negotiations will take place when the contracts are up for renewal or prior to that date

  • Ask your payers what impact ICD-10 will have on your payment schedule, medical review, auditing, and coverage

7) Conduct Staff Training

The only way you can possibly hope for a smooth transition with the least amount of denied claims and delayed payments is to make sure you and your staff is well-trained. Even those staff members who aren’t directly impacted by the new codes should be included and brought up to speed. Read our Complete guide to ICD-10 training for Physicians here to come up to speed within days.


  • Identify the level of training needed for staff (Different staff will need different levels of training depending on their use of ICD-9/ICD-10 coding)

  • Determine the amount of time it will take to have necessary staff trained

  • Identify the methods for staff training (The method of training may be based on the level of training needed)

  • Determine training costs

  • Identify downtime during training (if any)

  • Complete staff training 

8) Update Internal Processes


  • Update any internal processes, electronic or manual, used to conduct administrative transactions, e.g., submit claim, check eligibility, etc.

  • Update data collection tools and forms, e.g., encounter forms, superbills, etc.

  • Update data reporting processes, e.g., quality, public health, etc.

  • Update processes for writing orders, referrals, clinical reports, etc.

  • Update other processes for clinical data, e.g., problem lists, disease management registries, etc.

  • Perform all ICD-10 patient mapping before October 1. In case you start late, prioritize medical records for mapping. Start by mapping diagnosis for patients with appointments scheduled in October and work your way through the rest of them

9) Conduct Internal and external Testing

Besides making sure your vendors are ready for this transition, you’ll also want to perform a test run. Speak with them to determine what their testing processes are and their timeframe.

Verify that you can use your ICD-10-ready systems to:

  • Generate a claim

  • Perform eligibility and benefits verification

  • Schedule an office visit

  • Schedule an outpatient procedure

  • Prepare to submit quality data

  • Update a patient’s history and problems

  • Code a patient encounter


  • Conduct internal testing to ensure you can generate transactions with the ICD-10 codes within your system

  • Identify appropriate days/times for vendor to conduct internal testing, e.g., evenings, weekends

  • Conduct external testing with your trading partners to ensure the ICD-10 codes are sent and received properly

  • Review results and work with your vendor to correct any problems identified during the testing

Testing can be conducted even if your system isn’t ICD-10 ready. Look at the ICD-10 codes for the top conditions:

  • Look out for volume of conditions that constitute the major chunk of your revenue

  • Look at recent medical records for patients with these conditions and try coding them in ICD-10 for practice

  • Create a checklist for clinicians in cases of inadequate documentation

Keep a contingency plan in mind to submit claims incase your system isn’t ready by Oct 1st

  • For Medicare providers, options include:

  • Free billing software available from every MAC website

  • Part B claims submission by online provider portal (in about ½ of MAC jurisdictions)

  • Paper claims for providers who meet Administrative Simplification

  • Compliance Act Waiver requirements

  • Each of these options requires you to code in ICD-10

10) Implement ICD-10

Services discharged on or after October 1, 2015

Prior to the compliance deadline, establish a line of credit for unexpected interruptions/delays in claims processing and reimbursement

Monitor ICD-10 Submissions


  • Monitor submissions of ICD-10 codes to ensure they are being received properly

  • Monitor communications from trading partners for possible errors with codes

  • Monitor payments to ensure they are the expected amounts for the service(s) provided

  • Conduct audits of ICD-10 coding to ensure best possible codes are being used

  • Recognize key operational metrics that require ongoing monitoring

Final Considerations

There is no denying that the transition to ICD-10 will be challenging, and to be ready you’ve got to fight your urge to kick and scream your way through this transition. Instead, work as a team (including all of your vendors and payers) with a chosen leader who will always boost morale, provide comprehensive training, and make sure you’ve secured financing in case your revenue takes a big hit. If you follow the steps outlined in this guide, you and your practice should come out on top.