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FQHC/RHC/IHS-MOA Code Conversion Readiness Checklist

March 28, 2017

The following checklist has been prepared in anticipation of the Federally Qualified Health Centers (FQHC), Rural Health Clinics (RHC) and Indian Health Services/Memorandum of Agreement (IHS-MOA) code conversion to replace two-digit local codes with HIPAA-compliant procedure codes, which is scheduled to implement on October 1, 2017. This is intended to be a general guide, not a comprehensive project plan for providers. Medi-Cal recommends that providers use this checklist as a guideline to prepare themselves for the code conversion implementation.

Getting Ready for the FQHC/RHC/IHS-MOA Code Conversion Implementation:
Plan, Communicate and Review


Requires Immediate Attention


Recommended Start Date: April 2017
  • Review FQHC/RHC/IHS-MOA resources from Medi-Cal, CMS, vendors/billing contractors and other resources.
  • Notify your staff of the future code conversion implementation.
  • Assemble a code conversion project team to handle tasks and oversee the implementation. Be sure to include individuals from different business units affected by the code conversion.
    • Assign individual tasks to different members of the code conversion team such as the completion of system changes and testing, providing of training and education, and modification or development of policies/procedures and reports. At group meetings, assess progress of the implementation.
  • Assess the effects of the code conversion on your organization.
    • Assess the effect on all business units.
    • Identify current learning/skill gaps for coding staff.
  • Create a plan of action to address the code conversion.
    • Identify goals and develop a strategy to undertake the code conversion.
    • Keep concise and consistent messages as part of a communication strategy to educate stakeholders (upper management, IT staff and other transitory staff).
  • Business Partner Preparedness: Assess the timeframe it will take other billing service contractors to get ready for the code conversion. Assess contractor preparedness by using a timeline for upgrading the system. Providers are strongly encouraged to routinely check the monthly Medi-Cal Provider Bulletins as well as the Medi-Cal Learning Portal Training Calendar for announcements of upcoming training and webinars developed for FQHC/RHC/IHS-MOA providers.
  • Review the following code conversion crosswalks for a full description of the new HIPAA-compliant billing code sets:
FQHC/RHC/IHS-MOA Code Conversion Implementation and Testing

Recommended Start Date: May 2017
  • Conduct high-level training with clinicians and coders.
    • Offer designated coders and other personnel comprehensive instruction for training, mapping and auditing.
  • Begin internal testing and validate the system changes.
  • Begin external testing with vendors and other contractors.
  • Start reviewing coder and clinician preparation and start detailed coding.
  • Get vendors to complete implementation to production-ready systems.
  • Develop a back-up plan for continuing operation if a critical system fails or has any problem during code conversion implementation.
  • Create a communication plan for post code conversion implementation.
Preparing for Go-Live

Recommended Start Date: July 2017
  • Confirm with system contractor(s) that upgrades/enhancements in the contractor system have been completed.
  • Finalize all internal system upgrades and testing.
  • Make any adjustments to results of testing responses and do regression testing.
  • Revisit and conduct a test of the back-up plan to remain operational in case the implementation of the FQHC/RHC/IHS-MOA code conversion poses any problems.
  • Finalize external testing with outside contractors.
  • Coding staff should complete their comprehensive code conversion training prior to the go-live date. It is recommended for training to begin three months before implementation.
  • Resolve any problems/issues that may arise during testing that could have been overlooked.
  • Enact the code conversion communication plan.
  • GO-LIVE: Implement the code conversion by October 1, 2017.
Completing the FQHC/RHC/IHS-MOA Code Conversion Implementation and Post-Compliancy

(Must be completed by October 1, 2017)
  • Complete the code conversion implementation full compliance: October 1, 2017. Codes are required for services provided on or after October 1, 2017.
  • Monitor any errors as they occur.
  • Continue any coding staff training if learning gaps still exist.
  • Check the FQHC/RHC/IHS-MOA Code Conversion FAQs for further information.