Developing a Dual Coding Plan - Project Manager’s Perspective

CMS finally made the long awaited announcement that ICD-10 will be going live October 1, 2015.  No doubt one of the major tasks that an organization plans to undertake is dual coding.  In researching best practices and industry standards to develop a dual coding plan, there were a couple of things that became very obvious.  First there was minimal information on how to develop a dual coding plan and secondly there are considerable number of details that need to be fully vetted before an organization undertakes dual coding.     

The following outlines those essential elements that a project manager should take into account when developing a dual coding plan.


One of the first items that need to be considered is why dual coding is going to be done.  Exactly what are those objectives an organization would like to achieve from dual coding?  Defining specific objectives will provide the basis of what needs to be accomplished.  Here are some sample objectives:

  • Coders to gain experience in coding with ICD-10

  • Assess the financial impact in transitioning to ICD-10

  • Evaluate physician documentation and whether it will support coding with ICD-10

  • End to end testing with payers

Considering the first sample objective “coders to gain experience in coding . . .” a project manager would need to look at the predecessor and associated tasks, such as:  ensure coders have been trained on ICD-10 coding; coders would need access to necessary tools and resources (software updates, encoder, code books, references, etc.) so they could code in ICD-10; coders would need to know the process for dual coding; coders would need someone who could answer coding questions and assess their work; etc.   As you can see, this is an important initial step, as it will provide the context to define the tasks.


There are a number of different approaches for dual coding - concurrent dual coding, double coding, retrospective dual coding, coding natively, dual processing, etc.  Equally there are as many definitions for those terms as there are terms.  Many articles have been written on dual coding approaches, so it’s probably best to review some of those articles to get a good understanding of the different approaches that can be used.  The most important thing a project manager can do is to ensure the project team comes to agreement on the terms, definition of those terms, and how the approach will best meet their objectives.

Scope Definition

In order to define the scope for dual coding, consider what will be included and what will be excluded from the scope.  Referring back to the sample objective of “assess the financial impact . . .” the scope definition may include the top 15 DRG’s for the organization and all other DRG’s would be excluded from dual coding. 

The scope definition should specify what will be done as a part of dual coding and what will be excluded from dual coding.    Having this clearly defined will ensure there are no misunderstandings among the staff who are participating or supporting dual coding.


Two things that need to be considered for staffing are defining roles and identifying staff who will be assigned to those roles.  Looking at the sample objectives, the most obvious role that would be needed is a coder.  Other roles that may need to be considered to support these objectives is a coder trainer/supervisor who would take the lead for answering coder questions and evaluating coders’ work; an IT analyst to work on the systems/applications; a physician advisor or CDI analyst who would provide feedback on physician documentation; a financial analyst to review the financial impact, etc. 

As part of staffing, volumes should be reviewed.  If the scope is to dual code the top 15 DRG’s, then an assessment will need to be done to identify the number of encounters that would be targeted and the number of coders that will be needed to support the dual coding of those encounters.  An organization may need to hire additional coders or contract with a coding company so dual coding doesn’t negatively impact their DNFC (discharged not final coded). 

Lastly, assess the competency levels / training levels that staff may need.  Coders will need to be trained on ICD-10 specifics where the IT analyst may need to receive vendor training or review vendor materials to understand the overall system changes and impacts. 

Technical Requirements

In order to perform dual coding, an organization needs to assess their interfaces, encoder, coding, billing systems, etc. and the configuration of those systems so both ICD-9 and ICD-10 codes can be captured.  Any type of system upgrades or system configuration work is a major task and can take considerable time to complete.  It’s best to work closely with your vendor(s) and IT Department to understand these implications and how they will be utilized for dual coding. 


Since dual coding will impact normal operations, an organization needs to identify how the costs for dual coding will be covered.  Depending on what may be needed to support dual coding, the costs may be covered under a department’s operational budget, from the ICD-10 project budget, or a combination of the two.  

Time Line

Since the ICD-10 go live date has now been established and CMS has also provided target dates for testing.  Project managers will need to assess how dual coding will fit into their overall time line and be able to meet their project milestones.


As the dual coding plan is developed, it’s important to identify the “who, how, when, and where” of evaluating dual coding outcomes and providing feedback to the appropriate staff.  For example to provide feedback to physicians on their documentation, an organization may decide the CDI analyst will attend monthly physician meetings to review documentation findings from dual coding. 

Taking the time to develop a well thought-out dual coding plan will provide the necessary framework to ensure the dual coding initiative is a success. 

Katherine Owen-Gorgey
Senior Consultant



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