4 Lessons Learned from HIPAA 5010 That’ll Benefit Your ICD-10 Project

It’s a fact: ICD-10 has far more impact and involves far more change to people, processes and technology than HIPAA 5010. I’m of the opinion that much of the work expended and artifacts created during a HIPAA 5010 project - particularly test plans and test cases - will not lend direct value to an ICD-10 project. But I’m convinced that many organizations learned are a lot of 5010 lessons that can be leveraged in your ICD-10 project.

This view was supported by a number of letters to the National Committee on Vital Health and Statistics that shared some lessons learned from 5010 projects. Here’s a summary of these lessons I gleaned from two of these letters. I recommend reading these letters - see below - to learn the authors recommended approach for addressing each lesson learned.

1. Being “ready” was an essentially meaningless term
Vendor readiness was largely communicated via self-reporting and there was no “true” definition of vendor readiness in the healthcare community

2. Successful testing was a misnomer
Most testing was quantitative and not qualitative; too high level and not representative of the real world. There was a profound lack of transparency between all the stakeholders: providers, payers, clearinghouses and vendors.

3. Dearth of information and guidance
Most information publicly available and shared between constituents was informational and not pragmatic. There seemed to be a number of Chinese Walls erected between payers and providers, vendors and end users, etc. Everyone involved needs to understand why the changes are critical and where key business partner’s stand in the compliance timeline.

4. It wasn’t a “technical” problem with a solely technical solution.
It’s easy to always label challenges involving software as purely technical problems. But ICD-10, even more so than 5010, will require extensive collaboration between all the constituent stakeholders.

Those charged with implementing ICD-10 have a unique opportunity to learn from the lessons of the 5010 implementation. It’s up to those leading and managing ICD-10 projects to understand these lessons and demonstrate an approach to avoiding their repetition. 

References
“ICD-10: Avoiding the 5010 Pitfalls” Holly Louie, CHBME, June 20, 2012 http://www.ncvhs.hhs.gov/120620p36.pdf 

"5010 – Lessons Learned”, Holly Louie, CHBME, June 20, 2012
http://www.ncvhs.hhs.gov/120620p35.pdf