By Tori Sullivan

June 2010 – Y2K spurred the healthcare industry to update technology solutions and implement electronic health record systems. Many organizations moved from index card-based systems to paperless files. The implementation left health information offices neat and tidy, while providers pulled their hair out struggling to make the operational changes.

How often do vendors implement a new technology, train end-users with a focused tutorial and expect clients to include operational changes on their own? The answer is: more often than not.  Whether the work is out of scope, not part of a “standard implementation model,” or forgotten, operational change management is a necessary part of the process.

ICD-10 implementations are no different, requiring the inclusion of operational changes for clinical staff throughout each organization.  Vendors need to consider these operational changes when implementing technologies to accommodate ICD-10.

Clinical documentation improvement (CDI) programs are efforts to educate providers on improving the clinical quality of their documentation upfront rather than by retrospectively replying to coding queries. Improving clinical data quality is an ongoing effort and a necessity of the more expansive and specific ICD-10 data set. These CDI programs will become a staple to the management of electronic data in the ICD-10 era.

Also, pressure to appropriately code diagnoses and procedures based on the patient’s clinical record will require adequate exposure and practice coding medical charts in the ICD-10 format.  Clinical documents will need to meet the expanded language in order for the appropriate code to be assigned and finalized. Finally, claim rejections are expected to rise, either as a result of technology or coding errors. Expecting to deliver technology updated to meet the regulatory requirements alone will not suffice for a comprehensive implementation.

Operational change management practices may be added to existing implementation plans as described below.


Identifying operational impact areas is a standard practice for any project; however the results may not naturally be shared with the technology vendor’s project team. Work closely with your clients to review the acknowledged impact areas and confirm that the findings include a CDI program.

Gap Analysis

If a client does not currently have a CDI program in place, work with clients that do to develop a standard template and methodology you can share. Sample industry tool kits and reference information are also available through associations such as AHIMA.  Good clinical data is fundamental to the ICD-10 coding practices, potentially expanding the vocabulary of existing clinical templates and dictation practices. Once a CDI program is in place, it should become an ongoing and indefinite improvement effort.

Implementation and Testing

Client testing will be crucial because of the significance of this technology change. Testing will require active participation from both the vendor and client. Unlike other implementations, ICD-10 will require product knowledge as well as ICD-10 coding knowledge. Due to the nuances in moving from ICD-9 to ICD-10, business decisions regarding application and coding practices will be made by both the vendor and client. A testing strategy for each organization should include a review of business decisions that create technology or operational rules.  These business decisions, made by either the vendor or the client, can alter testing outcomes.  The collective knowledge of the product changes, as well as the coding changes, will prove useful when diagnosing a technology issue.

These additional decisions should be included in a test plan to comprehensively cover the test planning process:  

  • Resources: Clients will need to identify the physical location, technology, and staff to use during the testing and validation processes. Vendors will also need to plan staffing to support the end-user testing and validation efforts. Assigning a team of resources from both sides to work through the testing phase will reduce communication barriers.
  • Scheduling: Work with each client to schedule time dedicated to testing and validation, and to track the results and progress made towards completing the entire process.  This time is reserved for the client to discuss testing results, brainstorm issues, or ask questions about product functionality. As testing demand increases, the schedule of these meetings may need to be altered. Keep a dedicated time to regularly provide the client the opportunity to discuss questions outside of the standard support services arrangement.
  • Methodology: Develop a set of test scripts for each product that includes a description of the test activity, expected results, and space for collected results and end-user identification. Test results should be shared during the scheduled meetings. As test results show opportunities for documentation improvements, incorporate the CDI program into the testing process.

The ICD-10 implementation is manageable if work is planned and executed thoughtfully while keeping an eye on the looming deadline. Encouraging clients to begin CDI programs, and assisting along the way, will not only improve data processed, stored and referenced within applications; it will also provide clients with an opportunity to gain additional exposure to the code set.  Vendor and client partnering throughout the implementation will effectively incorporate product functionality as well as improve clinical documentation. The more “production like” exposure both vendor and client have to the code set prior to the productive use, the better the data will be on October 1, 2013.

About the Author

Tori Sullivan, MHA, RHIA, PMP, currently chairs the HIMSS ICD-10 Task Force and serves as Healthcare Manager for Capgemini U.S. LLC, in the Government Solutions/U.S. Public Healthcare sector. The co-author of Implementing ICD-10-CM/PCS for Hospitals (Chicago: AHIMA Press), Ms. Sullivan has presented on ICD-10 implementation topics for AHIMA, PMI, Financial Research Associates, LLC and HIMSS. In April 2010, Ms. Sullivan was given the Spirit of HIMSS award for her work as chair and her support of the Society’s overall financial systems initiatives.

You may reach Tori Sullivan at (571) 336-1668 or


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