1. Large (50+) Practice Implementation
A B C D E F G
Target Completion
1
Date √ Action Item Considerations Assigned To Progress Reports Date
2 Pre-2010
3 8/31/2009 Organize Implementation
4
Assign two point people within the
practice to organize and oversee the
5 implementation plan: one to focus on
ICD-10-CM and another person to focus
the technical/system implementations of
5010 and system testing
The point people will be responsible for
addressing key issues and formulating the
6 plan for implementation of their assigned
area.
Review the 5010 Final Rule: Effective
7 Date 1/1/2012
Review ICD-10 final rule: Effective Date
8 10/1/2013
Identify all areas that will impact the
practice such as the clinical areas, IT
9 systems, documentation, payer contracts,
policies, reports, etc.
Members to consider: managers
from billing office, practices,
managed care, clinical research, lab,
10 After reviewing the final rule and radiology, pharmacy, medical
identifying areas of impact, each point records, IT managers, compliance
person will select and appoint members officers and coding/reimbursement
to their work group/committee managers
If the practice uses a consultant to help
11 with coding or billing issues, invite them
to participate with the point people.
Prepare briefing materials related to the
scope of work that needs to be
12 accomplished for executive leadership
review.
Meet with physician and executive
leadership (executive committee). Medical Director, CEO, COO,
13 Discuss the impact it will have on the CFO/Controller, other executive
practice and obtain their support. managers
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

2. Large (50+) Practice Implementation
A B C D E F G
Establish a timeline and regular schedule
14 to report progress to executive
committee.
Identify who has final decision making
authority and which issues will need
15 executive committee approval (e.g.
communications with the physician
faculty, budget, funding, contracting, etc)
16 9/1/2009 Establish Communication Plan
Establish a communication plan—how the
committee and point people will Consider a webpage dedicated to the
17 communicate to all staff in relation to ICD-10 implementation project
implementation (e-mail, newsletter, where interested staff can go for
meetings, etc.). updates and information
Develop materials to disseminate to
18 providers and staff.
Begin communication to the entire
19 practice about the ICD-10 implementation
efforts
Schedule regular meetings with executive Consider adding ICD-10 updates to
20 committee, providers, managers and the agenda of routinely scheduled
departments to report progress. department or practice meetings.
21
22
Conduct Impact Analysis /
11/30/2009 Determine Costs
Conduct an in-depth impact analysis to
identify: 1) resources needed to
implement ICD-10-CM ; 2) all systems,
23 policies, forms, and people who will be Consider payer policies, contracts,
remotely or directly impacted by ICD-10; forms, systems, training, staffing,
and 3) estimate cost for each etc
Conduct a review of regulatory
requirements at each update (e.g.
24 Oct/Nov 2009) for ICD-10-CM
implementation. Identify changes and
impact to your plan.
Review new coding guidelines and review
crosswalks (government crosswalk
25 available; determine if your practice
require more enhanced vendor products
which will be available at a cost)
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

3. Large (50+) Practice Implementation
A B C D E F G
Systems might include: practice
management systems, billing
Review impact on systems within the systems, financial systems,
26 practice on processes and technology. encoders, coding look up programs,
Perform an in-depth review of systems claim scrubbing software, electronic
that will be affected and prepare a report medical records, electronic
for the executive committee. prescription software, PQRI, etc.
Access impact to current practice reports/
27 trending
Review vendor contracts: it may be
28 necessary to make amendments and/or
updates to these contracts
Contact system vendors to identify if the
vendors will be able to update software in
29 all needed areas or if new
software/hardware will be required.
Estimate potential costs. Discuss
contracts and if amendment is necessary
Vendor testing recommendations
(recommend staged testing): get on their
30 schedule NOW. Discuss receiving regular
communications about their readiness for
October 2013.
Contact clearing house to determine how
they plan to support transition. Discuss
31 testing, contracting, and on-going
communications.
Review hardware requirements for new
32 software and identify if hardware needs
to be updated or replaced.
Conduct a baseline review of current
documentation and its impact on ICD-10-
CM code selection. (perform audit using Consider ongoing/continued audits
33 ICD-10 codes to identify issues that will as provider education progresses to
impact documentation, EMR, policies and ensure improved, detailed medical
training) documentation.
Assess impact on Standard Operating
Procedures, Compliance policies, HIPAA
and Security. Review existing operations
34 within the practice and considered areas
of improvement—not just meeting the
compliance data but developing better
operations, performance
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

4. Large (50+) Practice Implementation
A B C D E F G
Based on audit results, develop
documentation improvement guides for
35 providers and clinical staff within the Audit after changes are made and
practice. implemented.
If introducing an EMR into the practice
36 begin the research and analysis on
systems available.
37 Establish a coordination plan for 5010
conversion and/or EMR implementation.
Identify requirements for ICD-10-CM
education (providers, clinical,
38 administrative, coding and billing).
Consider impact on staffing during As assessing, consider and evaluate
training sessions. budget costs
Review payer contracts and assess
39 possible delayed payments after
10/1/2013.
Identify who else needs to help with
40 achieving benefits – vendors, health
plans, outside trainers, consultants, etc.
41 12/31/2009 Estimate Budget
Estimate costs; identify funding for the
42 project. Consider bake sales ;-)
Establish budget and funding approval
43 from executive committee Take cookes ;-)
44 Software
45 Software license
46 Hardware procurement
47 Implementation/Deployment
Possible EMR upgrade or new
48 implementation
Superbills, lab requistions, lab
49 Forms changes and printing costs orders, treatment orders, etc
50 Staff training (codes and system changes)
51 Coding staff
52 Clinical staff
53 Physicians
54 Billers
55 Referral Coordinators/Financial Counselors
56 Administrative staff
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

5. Large (50+) Practice Implementation
A B C D E F G
Overtime costs due to training and
implementation. Cost of reduced patient
57 schedules during training of
providers/staff.
Cost of outside resources that may be
58 needed: temporary staffing, training,
consultants, etc
Cost to maintain CPC certification: 75
questions, computer based test that must
be successfully completed to maintain
59 certification with AAPC. Cost of $60 per
coder (for 2 tries). Proficiency testing
available October 1, 2012 and ends Sept
30, 2014.
Workflow process changes /coverage
60 during training
61 Testing
62 Delayed payments
63 Approval of budget
Communication of budget plans with
64 physicians or decision maker.
Develop an on-going budget re-
65 assessment process.
66 2010 Implementation Planning
Coordination of testing, scheduled
67 Determine sequencing of activities (i.e. printing, scheduled computer
7/31/2010 5010 project, EMR implementation). downtime, training, go-live
68 Create a timeline for implementation.
The timeline will include key elements for
69 preparedness
Timeline should also include metrics to
70 identify if milestone are met.
71 Determine use of crosswalks internally
Update current reports/trending that
72 were identified as being impacted by
ICD-10
Outline new processes needed because of
73 ICD-10
74 Identify additional quality efforts needed Conduct additional audits and
to ensure proper coding specificity review findings
75 Update operation and compliance policies
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

6. Large (50+) Practice Implementation
A B C D E F G
76 Update training tools for new providers
and staff; as well as other training tools.
Review opportunities that could impact
77 reimbursement, value based purchasing,
pay for performance and e-prescribing
78 Identify benefits of implementation.
79 Identify how to achieve benefits
80
81 8/31/2010 Contact System Vendors
Preliminary assessment of system
82 changes needed for ICD-10.
Determine if vendor will support changes
83 to systems.
Determine timeline for implementation of
84 changes.
Identify other changes to address issues
85 identified in gap analysis.
Determine anticipated testing time and
86 schedule (when will they start, how long
will they need, and what will be needed
for testing (e.g. sample claims).
87 Determine final costs for implementation.
88
Phase I training general overview
89 of ICD-10-CM, guidelines format and
structure and Phase II training will
9/30/2010 Two Phase Training Plan be in-depth based on specialty.
90 Identify staff training needs.
91 Clinical staff
92 Coding and billing staff
93 Referral Coordinators or Financial Counselors
94 Administrative staff
95 Physicians
96 Identify resources needed for training:
97 AAPC workshops, audio conferences
External training or Physician Specialty Societies
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

7. Large (50+) Practice Implementation
A B C D E F G
98 Training materials revised & updated
99 Identify internal resources to support training
100 Purchase of training materials
101 Develop Training Plan.
102 Establish a training schedule
Identify materials needed for ongoing
103 support after training
Determine if temporary staff is needed during
104 training
Develop communication plan for staff on
105 status of training
106 2011 Business Process Analysis
Identify all systems and processes that
107 currently use ICD-9 and conclude if they
6/30/2011 need to be upgraded to ICD-10, including:
108 Clinical
Administrative (e.g. Practice Mgmt and
109 Registration)
Billing (e.g. Computerized systems and
110 Superbills)
111 Other (e.g. Quality and Public Health)
Identify limitations in current use of
112 ICD-9-CM, including:
Not all diagnosis codes allowed by health
113 plans
More patients have complications and
114 comorbidities may require several diagnosis
codes to describe their condition
Review existing policies and procedures
115 related to ICD-9-CM.
Identify any changes needed in existing policy
116 and procedures, including:
117 - ICD-9-CM reporting
118 - Auditing of clinical documentation
- Review of specific clinical events –
119 adverse events
Identify impact to reports involving
120 ICD-10, including:
121 Internal
122 - Quality improvement
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

8. Large (50+) Practice Implementation
A B C D E F G
123 External
124 - Federal
125 Adverse drug events
126 Medical devices
127 Pay for performance
128 Research
129 - State
130 Public health
131 Newborn screening
Identify impact of ICD-10 on
132 payer/health plan contracts.
Identify contracts where reimbursement is tied
133 to particular diagnoses
Contact payers and discuss potential changes
134 to existing contracts
135 Determine timing of contract negotiations
136 Modify agreements as needed
Communicate contract changes to appropriate
137 staff
Conduct a gap analysis to determine
138 specific areas to improve/update.
Monitor payer policies (eg NCD and LCD
139 coverage changes)
Establish a plan for possible delayed
140 payments after go-live Oct 1, 2013.
141
142
143 2012 Phase I Training
144 9/30/2012 Begin Phase I training for:
145 Coding and billing staff
146 Physicians and other practitioners
147 Clinical Staff
148 Administrative Staff
149 Managerial Staff
150 Begin Phase I general training including:
151 Audio conferences
152 AAPC Local, Regional & Nat'l Meetings
153 Web portal training
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

9. Large (50+) Practice Implementation
A B C D E F G
154 Workshops and webcasts
155 Distance Learning
156
157 2013 Phase II Training
Begin Phase II of specialty specific
158 9/30/2013 training including:
159 Audio conferences
160 AAPC Local & Regional Conferences
161 AAPC National Conference
162 Workshops & webcasts
163 Distance Learning
164 Specialty Specific Training Sessions
165 Web portal training
166 Training Should include:
167 Coding and billing staff
168 Physicians and other practitioners
169 Clinical Staff
170 Administrative Staff
171 Managerial Staff
Certified Coders take AAPC Proficiency
172 Test to maintain certification. $60 per coder (2 tries to pass)
173
174
Deployment of Code by Vendors
5/31/2013 to Customers
Integrate software program(s) into your
175 systems.
Make internal customization after
176 deployment of code by vendor.
Integrate changes into production
177 systems.
Test systems with clearinghouses, payers,
electronic claims transmission with each
178 individual system (end to end). Finalizing
testing process.
Ensure vendors will maintain updates to
179 code during transition period.
180
181 8/31/2013 Outcomes Measurement
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

10. Large (50+) Practice Implementation
A B C D E F G
Measure coder productivity when using
182 ICD-10-CM.
Re-evaluate the medical record
183 documentation to ensure ICD-10-CM
coding can be achieved.
Internal testing of coding and billing staff
184 in ICD-10-CM proficiency.
Provide additional education and training
185 if deficiencies are identified.
186
187 2014 Implementation Compliance
188 9/30/2014 October 1, 2013 -“GO Live”.
189 Resolution of claim errors and denials.
Review insurance carrier payment
190 policies.
Conduct medical record documentation
191 reassessment.
Measure training and productivity
192 outcomes.
193 Provide retraining when needed.
Portions of the article and tables were excerpted from infomration published by American Academy of Professional Coders

11. Medium (11-49) Practice Implementation
Target Date P Action Item Considerations Assigned To Progress Reports Completion Date
Pre-2010 Organize the Implementation Effort
9/30/2009 Review ICD-10 Final Rule
Senior management briefing and
organization buy-in
Complete preliminary analysis of system
impact
Prepare briefing materials for providers
and staff to review related to the work and
scope of work that needs to be
accomplished
Identify senior manager project supporter
Establish senior management’s role in
completing project
Obtain support from all providers and
senior management
Talk with providers about ICD-10-CM and
the impact it will have on the practice
Identify all areas that will impact the
practice such as the clinical areas,
systems, documentation etc, and
share this information with providers
Establish regular schedule to report
progress to senior management
Coordinate briefing with the ICD-10
5010 project team
10/31/2009 Develop Communication Plan
Develop materials to disseminate to
managers, staff and providers
Include preliminary information on
timeframe and training
Conduct periodic briefings for staff or
include information in other
briefing/communication formats (i.e.
newsletters, e-mails, etc).
2010
5/31/2010 Conduct Impact Analysis

12. Medium (11-49) Practice Implementation
This is an in-depth impact analysis to
identify resources needed to
implement ICD-10-CM which should
include
Conduct a review of regulatory
requirements for ICD-10-CM
implementation
Identify at a high level existing systems
processes and technology that will be
impacted by ICD-10-CM
Determine requirements and
educational expectations by
Departments
Users
Systems, including internal and external
vendor information systems
Contact system vendors to identify if
the vendors will be able to update
software in all needed areas with
potential costs
Review hardware requirements for
new software and identify if hardware
needs to be updated or replaced
Identify funding for the project
Identify project manager
Establish approval from management
or providers
Determine sequencing of activities
(i.e. 5010 project, EMR
implementation).
Coordinate with 5010 project team
Coordinate with EMR implementation
project team
Review existing operations within the
practice and consider areas of
improvement—not just meeting the
compliance data but developing better
operations, performance, quality, etc.
Create a timeline for implementation.
The timeline will include key elements for
preparedness
Timeline should also include metrics to
identify if milestone are met

13. Medium (11-49) Practice Implementation
8/31/2010 Contact System Vendors
Preliminary assessment of system
changes needed for ICD-10-CM
conversion
Determine if vendor will support
changes to systems
Determine timeline for
implementation of changes
Determine final costs for
implementation
Identify other changes to address
issues identified in gap analysis
Identify when testing will occur
Determine anticipated testing time
and schedule (when will they start,
how long will they need, and what will
be needed for testing (e.g. sample
claims)).
2011
8/31/2011 Implementation Planning
Identify overall impact of ICD-10-CM.
Review the new coding guidelines.
Identify general impact of coding changes
Review crosswalks – government
available; more enhanced vendor
products
Determine use of crosswalks internally
Identify changes to current
reports/trending involving ICD-10
Identify any new processes needed
because of ICD-10
Identify additional quality efforts
needed to ensure proper coding
specificity
Review opportunities that could
impact reimbursement, value based
purchasing, and pay for performance.
Identify benefits of implementation

14. Medium (11-49) Practice Implementation
Identify specific benefits
Identify how to achieve benefits
Identify who else needs to help with
achieving benefits – vendors, health plans,
etc.
2012
9/30/2012 Phase I Training
Begin Phase I training for
Senior management
Cross functional teams
Coding and billing staff
Physicians and other practitioners
Clinical Staff
Administrative Staff
Phase I general training may include
Audio conferences
Local AAPC Chapter and AAPC Regional
Conferences
AAPC National Conference
Workshops
Distance Learning
AAPC Curriculum
8/31/2012 Business Process Analysis
Identify all systems and processes
that currently use ICD-9-CM and
conclude if they need to be upgraded
to ICD-10-CM, including
Clinical (e.g. Laboratory and Radiology)
Administrative (e.g. Practice Management
and Registration)
Billing (e.g. Computerized systems and
Superbills)
Other (e.g. Quality and Public Health)
Identify limitations in current use of
ICD-9-CM, including

15. Medium (11-49) Practice Implementation
Not all diagnosis codes allowed by health
plans
More patients have complications and
comorbidities may require several
diagnosis codes to describe their condition
Review existing policies and
procedures related to ICD-9-CM.
Identify any changes needed in
existing policy and procedures,
including
ICD-9-CM reporting
Auditing of clinical documentation
Review of specific clinical events – adverse
events
Identify impact to reports involving
ICD-10-CM, including:
Internal-Quality Improvement
External-Federal
Adverse drug events
Medical devices
Pay for performance
Research
External-State
Public health
Newborn screening
Identify impact of ICD-10 on
payer/health plan contracts
Identify contracts where reimbursement is
tied to particular diagnoses
Contact payers and discuss potential
changes to existing contracts
Determine timing of contract negotiations
Modify agreements as needed
Communicate contract changes to
appropriate staff
Conduct a gap analysis to determine
specific areas to improve/update
2013

16. Medium (11-49) Practice Implementation
9/30/2013 Education and Training, Phase II
Begin Phase II of specialty specific
training including
Audio conferences
Local AAPC Chapter and AAPC Regional
Conferences
AAPC National Conference
Workshops
Distance Learning
Specialty Specific Training Sessions
Training Should include
Coding and billing staff
Physicians and other practitioners
Clinical Staff
Administrative Staff
Managerial Staff
Take AAPC Proficiency Test to
maintain certification
4/30/2013 Policy Change Development
Identify opportunities to improve
processes
Make changes to policies as identified
in the gap analysis
Obtain approval from appropriate
source(s) for policy changes
Educate staff and physicians on policy
changes
8/31/2013 Outcomes Measurement
Measure coder productivity when
using ICD-10-CM
Re-evaluate the medical record
documentation to ensure ICD-10-CM
coding can be achieved.
Internal testing of coding and billing
staff in ICD-10-CM proficiency

17. Medium (11-49) Practice Implementation
Provide additional education and
training if deficiencies are identified
Deployment of Code by Vendors to
5/31/2013 Customers
Integrate software program(s) into
your systems
Make internal customization after
deployment of code by vendor
Integrate changes into production
systems
Test systems with clearinghouses,
payers, electronic claims transmission
with each individual system (end to
end).
Ensure vendors will maintain updates
to code during transition period
2014
9/30/2014 Implementation Compliance
October 1, 2013 -“GO Live”.
Resolution of claim errors and denials
Review insurance carrier payment
policies
Conduct medical record
documentation re-assessment
Measure training and productivity
outcomes
Provide retraining when needed

18. Small (4-10) Practice Implementation
Target Date Action Item Assigned To Progress Reports/Comments Completion Date
Pre-2010 Organize Implementation
Create a point person within
the practice to organize and
oversee ICD-10-CM
7/31/2009 implementation.
The point person will be
responsible for addressing key
issues and formulate the plan for
implementation.
Prepare briefing materials for
providers and staff to review
related to the work and scope
of work that needs to be
accomplished.
If the practice uses a
consultant to help with coding
or billing issues, invite them to
participate with the point
person.
Obtain support from all
providers.
Talk with providers about ICD-10
and the impact it will have on the
practice.
Establish a timeline and regular
schedule to report progress to
providers.
Schedule meetings with providers
or managers on a regular basis at
a minimum monthly to report
progress.
Identify all areas that will
impact the practice such as the
clinical areas, IT systems,
documentation etc., and share
this information with
providers.
Identify who has final decision
making authority
Establish Communication
8/31/2009 Plan

19. Small (4-10) Practice Implementation
Establish a communication plan
—how the committee or point
person will communicate to all
staff in relation to
implementation (e-mail,
newsletter, meetings, etc.).
Develop materials to
disseminate to providers and
staff.
11/30/2009 Conduct Impact Analysis
This is an in-depth impact
analysis to identify resources
needed to implement ICD-10-
CM which should include:
Conduct a review of regulatory
requirements for ICD-10-CM
implementation.
Review impact on systems within
the practice on processes and
technology. Perform an in-depth
review of systems that will be
affected and prepare a report for
the provider.
Systems might include:
practice management systems,
billing systems, financial
systems, encoders, coding look
up programs, electronic
medical records, etc.
Contact system vendors to
identify if the vendors will be
able to update software in all
needed areas with potential
costs.
Review hardware requirements
for new software and identify if
hardware needs to be updated
or replaced.

20. Small (4-10) Practice Implementation
Conduct a review of current
documentation and its impact
on ICD-10-CM code selection.
Based on audit results, develop
documentation improvement
guides for providers within the
practice.
Identify funding for the
project.
Establish approval from
management or providers.
Determine sequencing of
activities (i.e. 5010 project,
EMR implementation).
If using a practice management
system that transmits electronic
claims, contact the vendor for an
update on how they will support
transition.
If introducing an EMR into the
practice begin the research and
analysis on systems available.
Establish a coordination plan for
5010 conversion and/or EMR
implementation.
Identify requirements for
ICD-10-CM education
(providers, clinical,
administrative, coding and
billing).
Review existing operations
within the practice and
considered areas of
improvement—not just meeting
the compliance data but
developing better operations,
performance, quality, etc.
Create a timeline for
implementation.
The timeline will include key
elements for preparedness
Timeline should also include
metrics to identify if milestone are
met.

21. Small (4-10) Practice Implementation
12/31/2009 Estimate Budget
The budget should include all
costs associated with
implementation including:
Software
Software license
Hardware procurement
Implementation/Deployment
Possible EMR upgrade or new
implementation
Staff training
Coding staff
Clinical staff
Physicians
Administrative staff
Overtime costs due to training and
implementation
Workflow process changes
Testing
Communication of budget plans
with physicians or decision
maker.
Develop an on-going budget
re-assessment process.
2010
7/31/2010 Implementation Planning
Identify overall impact of ICD-10-
CM.
Review the new coding guidelines
Identify general impact of coding
changes
Review crosswalks – government
available; more enhanced vendor
products
Determine use of
crosswalks internally

22. Small (4-10) Practice Implementation
Identify changes to current
reports/trending involving ICD-10
Identify any new processes
needed because of ICD-10
Identify additional quality efforts
needed to ensure proper coding
specificity
Review opportunities that could
impact reimbursement, value
based purchasing, and pay for
performance
Identify benefits of
implementation.
Identify specific benefits
Identify how to achieve benefits
Identify who else needs to help
with achieving benefits – vendors,
health plans, etc.
8/31/2010 Contact System Vendors
Preliminary assessment of
system changes needed for
ICD-10.
Determine if vendor will
support changes to systems.
Determine timeline for
implementation of changes.
Determine final costs for
implementation.
Identify other changes to
address issues identified in gap
analysis.
Identify when testing will
occur.
Determine anticipated testing
time and schedule (when will
they start, how long will they
need, and what will be needed
for testing (e.g. sample
claims)).

23. Small (4-10) Practice Implementation
Development of the
9/30/2010 Training Plan
Identify staff training needs.
Identify resources needed for
training:
External training
Training materials
Internal resources available to
support training
Coordinate internal training
Phase I training general
overview of ICD-10-CM,
guidelines format and structure
and Phase II training will be
in-depth based on specialty.
Clinical staff
Coding and billing staff
Administrative staff
Physicians
Develop Training Plan.
Establish a training schedule
Identify materials needed for
ongoing support after training
Determine if temporary staff is
needed during training
Develop communication plan for
staff on status of training
2011
6/30/2011 Business Process Analysis
1. Identify all systems and
processes that currently use
ICD-9 and conclude if they
need to be upgraded to ICD-10,
including:
Clinical

24. Small (4-10) Practice Implementation
Administrative (e.g. Practice
Management and Registration)
Billing (e.g. Computerized systems
and Superbills)
Other (e.g. Quality and Public
Health)
Identify limitations in current
use of ICD-9-CM, including:
Not all diagnosis codes allowed by
health plans
More patients have complications
and comorbidities may require
several diagnosis codes to describe
their condition
Review existing policies and
procedures related to ICD-9-
CM.
Identify any changes needed in
existing policy and procedures,
including:
ICD-9-CM reporting
Auditing of clinical documentation
Review of specific clinical events –
adverse events
Identify impact to reports
involving ICD-10, including:
Internal
Quality improvement
External-Federal
Adverse drug events
Medical devices
Pay for performance
Research
External-State
Public health
Newborn screening
Identify impact of ICD-10 on
payer/health plan contracts.
Identify contracts where
reimbursement is tied to particular
diagnoses

25. Small (4-10) Practice Implementation
Contact payers and discuss
potential changes to existing
contracts
Determine timing of contract
negotiations
Modify agreements as needed
Communicate contract changes to
appropriate staff
Conduct a gap analysis to
determine specific areas to
improve/update.
2012
Policy Change
6/30/2012 Development
Identify opprotunities to
improve processes and make
changes to policies identified in
6.5
Obtain approval from
appropriate sources for policy
change
Educate staff and physicians on
policy changes
2013
8/31/2013 Outcomes Measurement
Measure coder productivity
when using ICD-10-CM.
Re-evaluate the medical record
documentation to ensure
ICD-10-CM coding can be
achieved.
Internal testing of coding and
billing staff in ICD-10-CM
proficiency.
Provide additional education
and training if deficiencies are
identified.

26. Small (4-10) Practice Implementation
Education and Training,
9/30/2013 Phase II
Begin Phase II of specialty
specific training including:
Audio conferences
Local chapter and AAPC Regional
Conferences
AAPC National Conference
Workshops
Distance Learning
Specialty Specific Training
Sessions
Training Should include:
Coding and billing staff
Physicians and other practitioners
Clinical Staff
Administrative Staff
Managerial Staff
Take AAPC Proficiency Test to
maintain certification.
2014
Implementation
9/30/2014 Compliance
October 1, 2013 -“GO Live”.
Resolution of claim errors and
denials.
Review insurance carrier
payment policies.
Conduct medical record
documentation re-assessment.
Measure training and
productivity outcomes.
Provide retraining when
needed.

27. Very Small (1-3) Practice Implementation
Target Date P Action Item Considerations Assigned To Progress Reports Completion Date
Pre-2010 Organize Implementation
7/31/2009 Review ICD-10 Final Rule
Create a point person within the
practice to organize and oversee
ICD-10-CM implementation.
The point person will be responsible for
addressing key issues and formulate the
plan for implementation.
Prepare briefing materials for
providers and staff to review related
to the work and scope of work that
needs to be accomplished
If the practice uses a consultant to
help with coding or billing issues,
invite them to participate with the
point person.
Obtain support from all providers.
Talk with providers about ICD-10 and the
impact it will have on the practice
Establish a timeline and regular schedule
to report progress to providers
Schedule meetings with providers on a
regular basis at a minimum monthly to
report progress
Identify all areas that will impact the
practice such as the clinical areas, IT
systems, documentation etc,, and
share this information with providers
Identify who has final decision
making authority
8/31/2009 Establish Communication Plan
Establish a communication plan—how
the committee or point person will
communicate to all staff in relation to
implementation (e-mail, meetings,
etc.).
Develop materials to disseminate to
providers and staff

28. Very Small (1-3) Practice Implementation
11/30/2009 Conduct Impact Analysis
This is an in-depth impact analysis to
identify resources needed to
implement ICD-10-CM which should
include
Conduct a review of regulatory
requirements for ICD-10-CM
implementation
Review impact on systems within the
practice including processes and
technology. Perform an in-depth review of
systems that will be affected and prepare a
report for the provider.
Systems might include: practice
management systems, billing systems,
financial systems, encoders, coding look
up programs, electronic medical records,
etc.
Contact system vendors to identify if
the vendors will be able to update
software in all needed areas with
potential costs
Review hardware requirements for
new software and identify if hardware
needs to be updated or replaced
Conduct a review of current
documentation and its impact on
ICD-10-CM code selection
Based on audit results, develop
documentation improvement guides
for providers within the practice
Identify funding for the project
Establish approval from providers.
Determine sequencing of activities (i.e.
5010 project, EMR implementation).
If using a practice management system
that transmits electronic claims, contact
the vendor for an update on how they will
support the transition
If introducing an EMR into the practice
begin the research and analysis on
systems available

29. Very Small (1-3) Practice Implementation
Establish a coordination plan for 5010
conversion and/or EMR
implementation.
Identify requirements for ICD-10-CM
education (providers, clinical,
administrative, coding and billing).
Review existing operations within the
practice and considered areas of
improvement—not just meeting the
compliance data but developing better
operations, performance, quality, etc.
Create a timeline for implementation
The timeline will include key elements for
preparedness
Timeline should also include metrics to
identify if milestone are met
12/31/2009 Estimate Budget
The budget should include all costs
associated with implementation
including
Software
Software license
Hardware procurement
Implementation/Deployment
Possible EMR upgrade or new
implementation
Staff training
Coding staff
Clinical staff
Physicians
Administrative staff including front office
staff
Overtime costs due to training and
implementation
Workflow process changes
Testing
Communication of budget plans with
physicians or decision maker

30. Very Small (1-3) Practice Implementation
Develop an on-going budget re-
assessment process
2010
5/31/2010 Implementation Planning
Identify overall impact of ICD-10-CM
Review the new coding guidelines
Identify general impact of coding changes
Review crosswalks – government
available; more enhanced vendor products
Determine use of crosswalks internally
Identify changes to current
reports/trending involving ICD-10
Identify any new processes needed
because of ICD-10
Identify additional quality efforts needed to
ensure proper coding specificity
Review opportunities that could impact
reimbursement, value based purchasing,
and pay for performance
Identify benefits of implementation
Identify specific benefits
Identify how to achieve benefits
Identify who else needs to help with
achieving benefits – vendors, health plans,
etc
6/30/2010 Contact System Vendors
Preliminary assessment of system
changes needed for ICD-10
Determine if vendor will support
changes to systems
Determine timeline for implementation
of changes.
Determine final costs for
implementation
Identify other changes to address with
vendor including issues identified in
gap analysis

31. Very Small (1-3) Practice Implementation
Identify when testing will occur
Determine anticipated testing time
and schedule (when will they start,
how long will they need, and what will
be needed for testing (e.g. sample
claims)).
6/30/2010 Development of the Training Plan
Identify staff training needs.
Identify resources needed for training
External training
Training materials
Internal resources available to support
training
Coordinate internal training
Phase I training general overview of
ICD-10-CM, guidelines format and
structure.
Clinical staff
Coding and billing staff
Administrative staff including front office
staff
Physicians
Phase II training will be in-depth
based on specialty
Coding and billing staff
Clinical Staff (if applicable)
Physicians
Develop Training Plan
Establish a training schedule
Identify materials needed for ongoing
support after training
Determine if temporary staff is needed
during training
Develop communication plan for staff on
status of training
2011
1/31/2011 Business Process Analysis

32. Very Small (1-3) Practice Implementation
Identify all systems and processes
that currently use ICD-9 and conclude
if they need to be upgraded to ICD-10,
including:
Clinical
Administrative (e.g. Practice Management
and Registration)
Billing (e.g. Computerized systems and
Superbills)
Other (e.g. Quality and Public Health)
Identify limitations in current use of
ICD-9-CM, including
Not all diagnosis codes allowed by health
plans
More patients have complications and
comorbidities may require several
diagnosis codes to describe their condition
Review existing policies and
procedures related to ICD-9-CM.
Identify any changes needed in existing
policy and procedures, including:
ICD-9-CM reporting
Auditing of clinical documentation
Review of specific clinical events – adverse
events
Identify impact to reports involving
ICD-10, including:
Internal
Quality improvement
External
Federal
Adverse drug events
Medical devices
Pay for performance
Research
State
Public health
Newborn screening
Identify impact of ICD-10 on
payer/health plan contracts

33. Very Small (1-3) Practice Implementation
Identify contracts where reimbursement is
tied to particular diagnoses
Contact payers and discuss potential
changes to existing contracts
Determine timing of contract negotiations
Modify agreements as needed
Communicate contract changes to
appropriate staff
Conduct a gap analysis to determine
specific areas to improve/update
2012
09/30/212 Phase I Training
Begin Phase I training for
Coding and billing staff
Physicians and other practitioners
Clinical Staff
Administrative Staff
Managerial Staff
Begin Phase I general training
including
Audio conferences
Local AAPC Chapter and AAPC Regional
Conferences
AAPC National Conference
Workshops
Distance Learning
AAPC Curriculum
6/30/2012 Policy Change Development
Identify opportunities to improve
processes
Make changes to policies as identified
in the gap analysis
Obtain approval from appropriate
source(s) for policy changes

34. Very Small (1-3) Practice Implementation
Educate staff and physicians on policy
changes
2013
Deployment of Code by Vendors to
5/31/2013 Customers
Integrate software program(s) into
your systems.
Make internal customization after
deployment of code by vendor
Integrate changes into production
systems
Test systems with clearinghouses,
payers, electronic claims transmission
with each individual system (end to
end).
Ensure vendors will maintain updates
to code during transition period
8/31/2013 Outcomes Measurement
Measure coder productivity when
using ICD-10-CM
Re-evaluate the medical record
documentation to ensure ICD-10-CM
coding can be achieved
Internal testing of coding and billing
staff in ICD-10-CM proficiency
Provide additional education and
training if deficiencies are identified
9/30/2013 Education and Training, Phase II
Begin Phase II of specialty specific
training including:
Audio conferences
Local chapter and AAPC Regional
Conferences
AAPC National Conference
Workshops

35. Very Small (1-3) Practice Implementation
Distance Learning
Specialty Specific Training Sessions
Training Should include:
Coding and billing staff
Physicians and other practitioners
Clinical Staff
Administrative Staff
Managerial Staff
Take AAPC Proficiency Test to
maintain certification.
2014
9/30/2014 Implementation Compliance
October 1, 2013 -“GO Live”.
Resolution of claim errors and denials
Review insurance carrier payment
policies
Conduct medical record
documentation re-assessment
Measure training and productivity
outcomes
Provide retraining when needed

36. Compatibility Report for Latest Copy of ICD-10 ACTION PLAN-REVISED.xls
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