CMS always takes a bit of a pounding when it comes to initiatives announced through the federal agency, and ICD-10 is no exception. Furious physicians have spent years decrying the necessity for switching to the new code set, but the reluctant acknowledgement that ICD-10 is indeed going to happen on October 1, 2014 hasn’t calmed the storm.
Now that it seems to be going forward, organizations are turning their attention to ensuring that the transition is done right. The Workgroup for Electronic Data Interchange (WEDI), which has partnered with CMS on an ICD-10 success initiative already, is joining the AMA and MGMA in asking CMS to bulk up its Medicare testing process to ensure a smooth switch for providers struggling with the technical and educational requirements.
In June of 2013, word leaked out that CMS was planning little in the way of external testing for Medicare, the nation’s largest payer. Medicare officials claimed to be satisfied with its technical preparations for the Version 5010 conversion, but the assertion immediately raised hackles across the industry. “The fact that they themselves won’t be testing from end to end, I consider to be ironic, and frankly, disappointing,” said Robert Tennant, Senior Policy Advisor for MGMA. “We’re spending billions of dollars on meaningful use but nothing on ICD-10 and expecting miracles to happen.”
After receiving a great deal of flak for its position, including complaints from MGMA and the American Hospital Association, CMS has backtracked a little on the announcement with the release of plans for front-end testing between Medicare Administrative Contractors and their business partners, the addition of an ICD-10 Testing Week in March isn’t enough to make sure that claims are appropriately transmitted and processed, WEDI asserts.
“Implementation of ICD-10 is much more complex than HIPAA Version 5010 or other HIPAA mandates to date,” WEDI Chairman Jim Daley reminds HHS Secretary Kathleen Sebelius in last week’s open letter. “The use of diagnosis and procedure codes impacts nearly every application and business process in hospitals, physician offices and health plans, as well as vendor applications and clearinghouse functions. As such, this mandate will require the most significant testing effort to date.”
During the switch to 5010, which was seen as a prerequisite and a training ground for ICD-10, “it was discovered that front-end testing alone did not uncover issues that arose when the transaction data was processed by downstream applications,” Daley writes. “What was thought of as a relatively simple front-end change turned out to be much more complex and it took several months to resolve implementation issues and required the government to issue two contingency plans.”
Providers remain in various stages of unpreparedness as the ICD-10 clock ticks down to less than ten months. Recent surveys have found that a majority of providers haven’t made adequate plans for the business impacts of the new code set, which is predicted to bring a loss of productivity to coders and a slew of denials and reprocessing requests from payers. WEDI’s own October preparedness survey shows that few providers or payers have dived into external testing yet, and plans to do so before the summer of 2014 are tentative at best.
“While engaging in end-to-end testing with every Medicare provider may not be practical, we do believe there must be sufficient and robust testing with a range of trading partners – hospitals, physicians (large and small practices from different medical specialties), clinics, clearinghouses and Medicare secondary payers,” Daley concludes. “This will give the industry a higher level of confidence that the Medicare claims processing system will operate as intended when ICD-10 goes live.”