Despite all the advances in automated technology, project management methodologies and experience gained over years of implementation work, making a major change in an organization’s production computer systems remains a disruptive and daunting operation.  This is particularly true for organizations that don’t go through such major changes frequently or don’t have the depth of resources and expertise on staff.  Success - or failure - can affect bottom lines, corporate cultures, work processes, and careers.  

With that in mind, here are some suggestions for successfully navigating the road to implementation.

• Plan, then plan some more, than plan some more – it’s essential to devote the time and effort to put together a plan at the appropriate level of detail to stay on track with resources, time and budget, and to determine how to handle governance, issues and scope control.  But don’t expect to deploy one plan and be finished, expect to revise the plan many times along the way.
• Set deadlines and milestones, determine owners, and invest the time to be sure those responsible meet their targets – this creates accountability for the project and allows for the identification of problems and errors early in the process when there is time to make corrections.  Also make the investment in detailing the exit criteria for each phase of the work, and to review the budget versus actual spend at the end of each phase.
• Clarify expectations and deliverables – this is probably one of the hardest areas to nail 100% so it’s worth investing the time. Don’t allow lack of clarity around who expected what from whom when and how to compromise the work of a high performing team, and make sure all deliverables are well defined and agreed to in advance so that when delivered they meet requirements and expectations.
• Test, test, test – providing adequate testing for complex cutovers can be difficult, but must be done to provide the needed level of comfort around readiness.  Take the time up front to apply best practices for test planning, test cases, and the appropriate types of testing to verify and validate readiness.  If there is an opportunity to perform a mock conversion, take it.  That’s another way to weed out potential problems and issues.
• Don’t forget the impact on people and processes – sometimes in the team’s zest to assure the readiness of the technology, fully understanding the impact of the cutover on people, work processes, forms and paperwork, and other nontechnical challenges associated with the cutover gets left in the dust, only to come back and bite a successful team after the fact.  Talk with end users and management, and make sure the impact is understood so there are no surprises.
• Training and documentation – people learn in many different ways, but ultimately some form(s) of training and documentation will be needed to prepare both the nontechnical and technical staff for their post-cutover roles and responsibilities.  This is often either overlooked, or short-cutted due to timing and budget, but can have a major impact on success.  The key is to determine what’s appropriate for the company, environment, type of cutover, project, users, etc.

This short list might be helpful to our clients and others who are thinking it’s time to start planning for the ICD-10 implementation:

• Get HIPAA 5010 in place
• Align with EHR
• Conduct a risk assessment
• Provide awareness and foundational education
• Gather an inventory of all contracts and systems
• Find a competent third party to help guide you through the process
• Get a computer-based tool to track the remediation and training process
• Plan how to report and track progress toward compliance
• Start contingency planning to avoid significant impact on your bottom line
• Use best practices for testing, training and change management.

These points build on previous blogs about the benefits of looking back over completed projects to see what we can learn. In this post I share some questions that one might pose about some of the “overall” indicators about how a project was planned and executed.  

• How accurate were the initial cost estimates and schedule?
• What was needed in budget and resources, above the original estimates, to complete the project successfully?
• How effective was the change control process?
• How effective was the issues management process?
• How effective was the project governance?
• How well were external dependencies understood at the outset of the project?
• Was the project a success?  Why or why not?
• Were the needs and expectations of the customer(s) met?
• How satisfied was the customer?
• Were the project objectives met?
• Were the business objectives met?

This one’s for my readers who really want to be a success.  Here’s a list of thoughts for you to use to strive to be a phenomenal success in the coming year and beyond!

• Have a purpose and a vision
• Have a positive attitude and be enthusiastic
• Go above and beyond
• Learn from the past
• Take initiative
• Have empathy and compassion
• Work well as a member of a team
• Pay attention
• Be a creative thinker
• Have faith

As Apex3 is working with several strategic partners to bring our IT expertise to the health care community, this blog will, from time to time, devote space to the ICD-10 transition.  Here’s a list of important actions health care providers should be taking now, with an eye to the transition looming in October 2013…

• Form executive steering committee and set expectations for transition requirements

• Create a governance structure for the ICD‐10 program

• Perform an impact assessment and identify potential changes to existing work flow and business processes (6 months)

• Collect information from each department staff members who will need ICD-10 training

• Evaluate the effect of ICD-10 on other planned or on-going projects (e.g., 5010 transition, EHR adoption and Meaningful Use)

• Determine the business and technical implementation strategy 

• Estimate costs associated with the implementation, such as software, hardware, and staff training 

• Evaluate contracts and contact vendors, clearinghouses, and billing services to understand their readiness and plans

• Determine anticipated testing time and include in the transition schedule 

Personal Note From Mark Davison As We Enter 2012

I want to wish all readers of my blog a happy and healthy new year.  Looking back on 2011, I was thinking about the year just past, and how it was.  Many thoughts run through my mind - challenges and opportunities, accomplishments and achievements, but also disappointments and sadness – a reminder that this year like all others was filled with moments to celebrate and others that will be remembered with some pain.  Hopefully my writings here in the blog have been helpful to many of you who are seeking to find interesting reading, tips, suggestions and ideas on consulting, project management, working with people, and achieving successful outcomes.  

Whether your year has been a good one or not, in 2012 I encourage you to try to build on your successes, using them as a foundation to be even more successful and to do more good in the coming year.  Similarly, take some time to think about and learn from your disappointments and mistakes, and try to do things differently next year so you can get different results.  Finally, keep learning and pushing yourself to higher levels of accomplishment, and remember the following 5 “short lessons of interaction”  when dealing with others … to be flexible, tolerant, patient, understanding and nice - as you enter 2012.  Inspire others to do the same!  

Happy New Year!

Project Lessons Learned – Part 3

Human Factors

These points build on previous blogs about the benefits of looking backward over projects to see what we’ve learned.  In this post I share some questions that focus on the human aspects of a project.  The answers can provide insights into what to do/not do on the next project.

• Was the project organization effective?
• Did the project manager have the right reporting relationships?  Why or why not?
• How effectively did the organization support the project?
• How effective was the project manager?
• How effective was the staffing of the project team?
• What training was provided?
• What skills and experience were lacking on the project team?
• How effective was the project team in achieving the goals and objectives?
• How well did the team members work with each other?
• How well did the team members work with others – internal and external?
• How effective were project communications within the project team?
• Did the team have sufficient resources?
• How effective was the team in making and honoring commitments?
• What types of conflicts came up?  How were they resolved within the team?
• How effective was the team in resolving conflicts?
• How effective was the team in obtaining cooperation of end users and functional areas?
• How did the team exercise authority over resources and commitments to meet objectives?
• How did the team create accountability to assure meeting targets and deadlines?

Project Lessons Learned – Part 2

Project Execution and Delivery

Almost all of our projects benefit from looking backward over the project life cycle to see what we’ve learned.  In this post I want to share some questions that can be asked about the execution and delivery aspects of a project.  The answers can provide insights into what to do/not do on the next project.

• Did the project stick to its original goals?
• How manageable were changes in direction?
• How well managed were project baselines around scope, time and budget?
• How well were design changes managed?
• How well were risks managed?
• How well were issues managed?
• Was progress tracked against baselines?
• How frequently was progress reported?  To whom?
• How well were internal resources managed?  How were they held accountable for accomplishments and deliverables?  Did they meet requirements for budget, schedule, quality and performance?
• How well were contracted vendors managed?  How were they held accountable for accomplishments and deliverables?  Did they meet requirements for budget, schedule, quality and performance?
• How well were stakeholders satisfied?
• How well did the deliverables and results satisfy the requirements, goals and objectives? 

For our Healthcare Clients:  We republish the following CMS Statement released November 17, 2011, regarding the 90 day period of enforcement discretion for compliance with new HIPAA Transaction Standards...

CMS STATEMENT   

FOR IMMEDIATE RELEASE        

Thursday, November 17, 2011                           

Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services Announces 90-Day 

Period of Enforcement Discretion for Compliance with New HIPAA Transaction Standards 

Today the Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services (OESS) 

announced that it would not initiate enforcement action until March 31, 2012, with respect to any HIPAA covered 

entity that is not in compliance  with the ASC X12 Version 5010 (Version 5010), NCPDP Telecom D.0 (NCPDP 

D.0) and NCPDP Medicaid Subrogation 3.0 (NCPDP 3.0) standards. Notwithstanding OESS’ discretionary 

application of its enforcement authority, the compliance date for use of these new standards remains January 1, 

2012 (small health plans have until January 1, 2013 to comply with NCPDP 3.0). 

CMS’ Office of E-Health Standards and Services is the U.S. Department of Health and Human Services’ 

component that enforces compliance with HIPAA transaction and code set standards. 

OESS encourages all covered entities to continue working with their trading partners to become compliant 

with the new HIPAA standards, and to determine their readiness to accept the new standards as of January 1, 2012.  

While enforcement action will not be taken, OESS will continue to accept complaints associated with compliance 

with Version 5010, NCPDP D.0 and NCPDP 3.0 transaction standards during the 90-day period beginning January 

1, 2012.  If requested by OESS, covered entities that are the subject of complaints (known as “filed-against 

entities”) must produce evidence of either compliance or a good faith effort to become compliant with the new 

HIPAA standards during the 90-day period.   

OESS made the decision for a discretionary enforcement period based on industry feedback revealing that, 

with only about 45 days remaining before the January 1, 2012 compliance date, testing between some covered 

entities and their trading partners has not yet reached a threshold whereby a majority of covered entities would be 

able to be in compliance by January 1.  Feedback indicates that the number of submitters, the volume of 

transactions, and other testing data used as indicators of the industry’s readiness to comply with the new standards 

have been low across some industry sectors.  OESS has also received reports that many covered entities are still 

awaiting software upgrades.   

Version 5010, NCPDP Telecom D.0 and NCPDP Medicaid Subrogation 3.0 standards represent significant 

improvement over the current standard versions.   NCPDP Telecom D.0 addresses certain pharmacy industry needs.  

NCPDP Medicaid Subrogation 3.0 allows state Medicaid programs to recoup payments for pharmacy services in 

cases where a third party payer has primary financial responsibility.   Version 5010 in particular provides more 

functionality for transactions such as eligibility requests and health care claims status   Implementation of Version 

5010 also is a prerequisite for using the updated ICD-10 CM diagnosis and ICD-10-PCS inpatient procedure code 

set in electronic health care transactions effective October 1, 2013.  

Links to information on Version 5010, NCPDP D.0 and NCPDP 3.0 are available at www.cms.gov/ICD10 

By:  

DEPARTMENT OF HEALTH & HUMAN SERVICES 

Centers for Medicare & Medicaid Services 

Room 352-G 

200 Independence Avenue, SW 

Washington, DC  20201