The Role of Compliance in ICD-10 Implementation

  1. Implementing Policies, Procedures and Standards of Conduct
    Compliance departments should assess the group’s current policies and ask these key questions:
    • Are the practice’s current standards and policies up-to-date, and do they include all issues that will impact ICD-10?
    • Have all coding policies and procedures been reviewed to ensure compliance to ICD-10 documentation guidelines?
    • Have IT systems been updated to enable the submission of ICD-10 codes?
  2. Designating a Compliance Officer or Compliance Committee
    Leadership within your ICD-10 committee is vital. The compliance officer should:
    • Be a part of the ICD-10 committee
    • Play a critical role in the decisions that affect ICD-10
    • Report ICD-10 initiatives to the governing body and/or the compliance committee
  3. Conducting Effective Training and Education
    • Has education been provided to every employee, from seasoned to new employees?
    • Are employees aware of how the change will affect their daily workflow and duties?
    • Have coders and physicians received adequate training on the documentation requirements for ICD-10?
  4. Conducting Internal Monitoring and Auditing
    • Periodic chart audits should be conducted to ensure that documentation supports the ICD-10 code being billed.
    • The monitoring and auditing plan should include a review of claims for improper payments.
    • Systems should be monitored to ensure compliance with ICD-10.
    • IT should be involved with implementation of ICD-10 and compliance process.
  5. Responding Promptly to Detected Offenses and Developing Corrective Action
    • Has a response plan been developed if physician documentation is not adequate for ICD-10 billing?
    • Is there a contingency plan in place if claims cannot be billed on October 1, 2014?
  6. Developing Effective Lines of Communication
    • Develop an easy process to report issues of non-compliance concerning ICD-10.\
    • Create a communication plan that disseminates changes to policies and procedures so staff can integrate them into their daily operations.
  7. Enforcing Standards Through Well-Publicized Disciplinary Guidelines
    • Have disciplinary standards been updated to include non-compliance with ICD-10?

Strategic thinking and a high-level risk assessment conducted by your compliance team will help prepare your organization to implement the changes and gain the benefits that the robust ICD-10 code set brings. The OIG model should be reviewed against your existing compliance program to help you understand the elements the government uses to make judgments on the effectiveness of compliance programs.


1 Department of Health and Human Services Office of Inspector General OIG Compliance Program for Individual and Small Group Physician Practices. Federal Register / Vol. 65, No. 194 / Thursday, October 5, 2000 / Notices. pgs: 59434-59452.


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